GRACE T. MAGDALUYO AND ANGELES CANDELARIO, PETITIONERS, VS. GLORIA M. QUIMPO, EDITHA M. PEREZ, ROBERTO T. MIJARES, VENECIA Q. MIJARES, BUTCH MIJARES, NANETTE MIJARES, JOFELDA M.…

Magdaluyo versus Quimpo

The Case

This is a petition for review on certiorari brought by Grace Magdaluyo and Angeles Candelario against Gloria Quimpo, Editha Perez, Roberto Mijares, Venecia Mijares, Butch Mijares, Nanette Mijares, and Jofelda Mijares. The respondents sued the petitioners in the Regional Trial Court of Kalibo, Aklan for recovery of possession and ownership and for the declaration of nullity of a document of assignment, with damages, over a contested portion of land. The case matters to a reviewee because it teaches, in the cleanest possible way, the doctrine of res judicata — the rule that a matter once finally decided binds the whole world — and because it shows how a final judgment on a bigger parcel quietly settles the fate of a smaller lot carved out of it.

Procedural History

The respondents filed their complaint on April 15, 1993 with the Regional Trial Court of Kalibo, Aklan, Branch Six. After trial on the merits, the trial court rendered judgment on May 31, 1995 in favor of the respondents, declaring them the lawful owners and possessors of the land, declaring the deed of assignment null and void, ordering Grace Magdaluyo to vacate and to restore possession to the respondents, and ordering the defendants jointly and severally to pay litigation expenses and costs. The petitioners appealed to the Court of Appeals, which on January 27, 1999 affirmed the trial court in full and later denied the petitioners' motion for reconsideration. The petitioners then came to the Supreme Court by petition for review on certiorari, assigning several errors. The Supreme Court denied the petition for lack of merit.

Facts

The respondents claimed to be the lawful owners and possessors of a large residential land in Poblacion, Kalibo, Aklan, declared in the name of the deceased Encarnacion Mijares under a tax declaration. They alleged that they and their predecessors had possessed the land peacefully, publicly, adversely, exclusively, and in good faith, in the concept of owner, for more than forty years. They said the petitioners unlawfully entered the contested portion and built a structure without their consent, dispossessing them, and refused to leave despite demands. The respondents added that Grace Magdaluyo claimed to have acquired the land in 1986 from Angeles Candelario by an Assignment of Right, but that this assignment was void because Candelario neither owned the contested area nor had any right or interest in it, and because Magdaluyo was an assignee in bad faith who knew the flaw in her assignor's title.

For their part, the petitioners alleged that Magdaluyo acquired the rights from Candelario on June 26, 1986, that Candelario had possessed the land peacefully and continuously for more than thirty years, that Magdaluyo held a miscellaneous sales application given due course by the Bureau of Lands, and that she had declared the land for taxation and paid realty taxes. In their reply, the respondents stated that the land in question is an accretion to Lot 173, covered by a transfer certificate of title in their names, and they admitted that Candelario's house stood on the land.

At pre-trial, the parties agreed to the appointment of a court commissioner to delimit the land in relation to cadastral Lot 173. The commissioner's report, approved by the trial court, stated that the lot in question is part or within the metes and bounds of the land involved in a prior case, Civil Case Number 2132, entitled Rosario Adante versus Roberto Mijares and others. In that earlier case, the trial court had declared the Adantes owners of a portion of the accreted land and the Mijareses owners of another portion. The Court of Appeals affirmed that decision in full, and this Court denied the petition for review and later denied reconsideration with finality.

Issues

• Whether or not the disputed land is an old dried river bed of public dominion, so that its disposition falls within the control of the Bureau of Lands.
• Whether or not the complaint should be dismissed for non-exhaustion of administrative remedies and for failure to include the Bureau of Lands as an indispensable party.
• Whether or not the Bureau of Lands certification that the land is agricultural disposable land confines the issue to possession rather than ownership.
• Whether or not the petitioners' physical and continuous possession for more than thirty years, coupled with the approval of their miscellaneous sales application, entitles them to the land.

Applicable Provisions

Rule 45, Section 1 of the 1997 Rules of Civil Procedure, invoked by the respondents, provides:

Section 1. Filing of petition with Supreme Court. A party desiring to appeal by certiorari from a judgment or final order or resolution of the Court of Appeals, the Sandiganbayan, the Regional Trial Court or other courts whenever authorized by law, may file with the Supreme Court a verified petition for review on certiorari. The petition shall raise only questions of law which must be distinctly set forth.

This provision bears on the case because the respondents argued that the petition raised no question of law, and the Court resolved the petition on the strength of a prior final judgment rather than by re-examining the facts.

Ruling

On the first issue, the Court did not disturb the findings below that the land formed part of the parcel already adjudicated. On the second and third issues, the Court held that the petition must fail because the matter had already been settled. As the respondents correctly pointed out, the land subject of the petition is part of a bigger parcel that had already been awarded to them in a previous case decided with finality by this Court. The Court anchored its ruling on the commissioner's finding that the lot in question is within the metes and bounds of the land involved in the earlier case between Rosario Adante and Roberto Mijares, which had been affirmed by the Court of Appeals and by this Court, with reconsideration denied with finality. On the fourth issue, the petitioners' claim of long possession and an approved sales application could not prevail over a final judgment. The Court declared that the prior decision now binds the whole world.

Doctrine

A final judgment rendered by a court of competent jurisdiction is conclusive upon the parties and their successors in interest, and it binds the whole world. When a smaller lot is shown to be part and within the metes and bounds of a bigger parcel already adjudicated with finality, the earlier judgment controls the ownership and possession of that smaller lot, and a later action relitigating the same land must fail. A petition for review on certiorari under Rule 45, Section 1 must raise only questions of law, and where the core controversy has already been passed upon and finally settled, the Court will deny the petition for lack of merit.

Disposition

The Supreme Court denied the petition for lack of merit, leaving standing the judgment declaring the respondents the lawful owners and possessors of the land and the assignment null and void.

Remember This

Memorize the line: the land subject of the petition is part of a bigger parcel already awarded to the respondents in a previous case decided with finality, and that decision now binds the whole world. Examiners use this case to test res judicata and the finality of judgments, and to remind candidates that a Rule 45 petition must raise only questions of law.