JUSTINA DE LA CRUZ, ET AL., PLAINTIFFS-APPELLANTS, VS. CARMEN QUEVEDO, ET AL., DEFENDANTS-APPELLEES.

De la Cruz versus Quevedo

The Case

This is a case about a five-hectare parcel of land in Ilocos Norte and a dispute between the Cruz family and the Quevedo family that began in 1932 and, by the time of this decision, had already produced three prior litigations won by the Quevedo side. The heirs of Teodora de la Cruz filed an action of reivindicacion, seeking to recover the land from the Quevedos on the theory that they had been illegally deprived of it. The case matters because it shows how a clerical error in a court's transcription of an earlier decision can be exploited to reopen a controversy that res judicata should have closed, and it teaches that a final judgment of the Court of Appeals in a land registration case binds the parties on the question of ownership.

Procedural History

The controversy began in the Court of First Instance of Ilocos Norte in a land registration case, where Teodora de la Cruz prevailed. On review, the Court of Appeals approved the registration but modified it by sustaining the opposition of Santos Quevedo and adjudicating to him the five-hectare portion he claimed. That decision became final. When the records returned to the Court of First Instance, Cruz was ordered to submit an amended plan excluding the portions adjudicated to Quevedo and the other successful oppositors. Cruz refused and filed a petition for certiorari in the Supreme Court, which was dismissed in January 1940. Cruz then filed a petition to review the award on the ground of fraud, which was denied, and her appeal from the denial was disallowed. She brought the matter to the Supreme Court by petition for mandamus, which was dismissed in June 1942. Quevedo later obtained a court decree allowing a government surveyor to prepare the technical plan, and in December 1946 the court ordered the Sheriff to place Quevedo in possession, which was done. In September 1950, the heirs of Cruz initiated the present action of reivindicacion in the Court of First Instance. The lower court dismissed the action, and the plaintiffs appealed to the Supreme Court.

Facts

In October 1932, Teodora de la Cruz, predecessor of the present plaintiffs, filed with others an application for registration of a parcel of land of more than ninety hectares in Ilocos Norte. Among the oppositors was Santos Quevedo, ascendant of the present defendants, who asserted ownership over a five-hectare portion. Cruz prevailed in the Court of First Instance, but on review the Court of Appeals approved the registration while sustaining Quevedo's opposition and adjudicating the five-hectare portion to him. That decision became final.

When the records returned to the Court of First Instance, Cruz was required to submit an amended plan excluding the portions adjudicated to Quevedo and the other successful oppositors. Cruz refused, maintaining that the portion adjudged to Quevedo was not included in her original plan. She brought a certiorari petition to the Supreme Court, which was dismissed in January 1940. That 1940 decision, however, in quoting the dispositive portion of the Court of Appeals decision, omitted or rephrased through clerical mistake the clause adjudicating to the oppositors the portions they claimed. The official copy of the Court of Appeals decision attached to the registration case contained the omitted portion.

After 1940, Quevedo took steps to carry out the Court of Appeals decision. Cruz again filed a petition to review on the ground of fraud, which was denied because the alleged fraud was intrinsic. Her appeal was disallowed, and her petition for mandamus to the Supreme Court was dismissed in June 1942. Cruz continued to refuse to submit an amended plan, so Quevedo obtained a court decree permitting a government surveyor to prepare the technical plan. Upon submission of the plan, the court in December 1946 ordered the Sheriff to put Quevedo in possession, which was done. Four years later, in September 1950, the heirs of Cruz initiated this action of reivindicacion, alleging illegal deprivation of the land.

Issues

• Whether or not the five-hectare parcel of land was adjudicated to Santos Quevedo in the original registration case.
• Whether or not the decision of the Court of Appeals in the registration case constitutes res judicata on the question of Quevedo's ownership.
• Whether or not the plaintiffs may now relitigate the question of ownership in an action of reivindicacion.

Applicable Provisions

The decision does not quote any statutory provision. It applies the doctrine of res judicata, which provides that a final judgment on the merits is conclusive as to the rights of the parties and their privies, and constitutes an absolute bar to a subsequent action involving the same claim, demand, or cause of action. The Court also cites the rule that only extrinsic or collateral fraud gives rise to reopening, and that perjury is not extrinsic fraud.

Ruling

On the first issue, the Court held that the land was indeed adjudicated to Santos Quevedo in the original registration case. The Court found that the land was identically the same parcel described in Quevedo's opposition and claim in the registration case. The plaintiffs relied principally on the mistaken quotation in the 1940 decision, but the Court held that the official copy of the Court of Appeals decision attached to the registration case contained the omitted portion, and that the 1940 decision itself acknowledged that certain parcels had been adjudicated to the oppositors. The Court quoted the Court of Appeals decision as follows:

Por las consideraciones expuestas, modificamos la sentencia apelada, estimando las oposiciones de Felix Ponce, de los herederos de David Flor y de Santos Quevedo, desestimando todas las demas, y adjudicando a ellos las porciones reclamadas por los referidos opositores Ponce, Flor y Quevedo, sujeto a los contratos exhibitos O, P y Q otorgados entre aquellos y los opositores llamados zanjeros. Los solicitantes deben presentar un plano enmendado de acuerdo con esta decision, y dentro del plazo que el Juzgado inferior designe.

On the second issue, the Court held that the Court of Appeals decision constitutes res judicata on the point of Quevedo's ownership. The Court stated that it was now too late to aver that the land was not included in the registration case, or was different from the lot claimed, or that Quevedo had no title to it.

On the third issue, the Court held that the plaintiffs may not relitigate the question of ownership in an action of reivindicacion. The Court noted that the cases cited by the appellants, holding that one who lost in a registration case may thereafter relitigate and sue the oppositors in a reivindicacion, were cases wherein the land was not adjudged in favor of the latter in the registration proceeding. Here, the land had been adjudged to Quevedo, so the action could not prosper.

Doctrine

A final judgment of the Court of Appeals in a land registration case, adjudicating a parcel of land to an oppositor, constitutes res judicata on the question of ownership and bars a subsequent action of reivindicacion by the losing party. A clerical error in the transcription of a dispositive portion in a later decision does not nullify the final judgment where the official copy of the decision contains the omitted portion and the later decision itself acknowledges the adjudication. Only extrinsic or collateral fraud gives rise to reopening of a judgment; perjury is not extrinsic fraud. A party who lost in a registration case may relitigate and sue the oppositors in a reivindicacion only where the land was not adjudged in favor of the latter in the registration proceeding.

Disposition

The Supreme Court affirmed the dismissal of the action of reivindicacion, with costs against the appellants.

Remember This

The single line worth memorizing is that a final judgment of the Court of Appeals in a land registration case adjudicating land to an oppositor is res judicata on ownership and cannot be collaterally attacked through a clerical error in a later decision. Examiners like to use this case to test the doctrine of res judicata and the distinction between intrinsic and extrinsic fraud in the context of land registration and reivindicacion.