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Catholic Vicar Apostolic of The Mountain Province v. CA

The Catholic Vicar Apostolic filed to register title to four lots in La Trinidad, Benguet, including Lots 2 and 3 claimed by heirs of Juan Valdez and Egmidio Octaviano. The land registration court confirmed the Vicar's title, but the Court of Appeals reversed regarding Lots 2 and 3. The heirs then sued the Vicar, arguing the ownership issue was already decided. The Vicar claimed res judicata did not apply. The Supreme Court ruled that res judicata did apply since the appellate court already examined possession and found the Vicar did not meet requirements for acquisitive prescription of the disputed lots. The Court of Appeals was correct to treat its prior decision as governing the current cases.

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120 views2 pages

Catholic Vicar Apostolic of The Mountain Province v. CA

The Catholic Vicar Apostolic filed to register title to four lots in La Trinidad, Benguet, including Lots 2 and 3 claimed by heirs of Juan Valdez and Egmidio Octaviano. The land registration court confirmed the Vicar's title, but the Court of Appeals reversed regarding Lots 2 and 3. The heirs then sued the Vicar, arguing the ownership issue was already decided. The Vicar claimed res judicata did not apply. The Supreme Court ruled that res judicata did apply since the appellate court already examined possession and found the Vicar did not meet requirements for acquisitive prescription of the disputed lots. The Court of Appeals was correct to treat its prior decision as governing the current cases.

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CATHOLIC VICAR APOSTOLIC OF THE MOUNTAIN

PROVINCE v. COURT OF APPEALS, HEIRS OF EGMIDIO


OCTAVIANO AND JUAN VALDEZ

G.R. No. 80294-95 September 21, 1988


Gancayco, J.

[Loo, Lissa Marie G.]

FACTS: The Catholic Vicar Apostolic of the Mountain Province (VICAR for brevity)
filed with the Court of First Instance of Baguio Benguet an application for
registration of title over Lots 1, 2, 3, and 4 in Psu-194357, situated at Poblacion
Central, La Trinidad, Benguet, said Lots being the sites of the Catholic Church
building, convents, high school building, school gymnasium, school dormitories,
social hall, stonewalls, etc.

The Heirs of Juan Valdez and the Heirs of Egmidio Octaviano filed their Answer/
Opposition on Lots Nos. 2 and 3, respectively, asserting ownership and title
thereto. After trial on the merits, the land registration court promulgated its
Decision confirming the registrable title of VICAR to Lots 1, 2, 3, and 4. The Court
of Appeals rendered its decision reversing the decision of the land registration
court and dismissing the VICARʼs application as to Lots 2 and 3, the lots claimed
by the two sets of oppositors in the land registration case (and two sets of
plaintiffs in the two cases now at bar), the first lot being presently occupied by the
convent and the second by the womenʼs dormitory and the sisterʼs convent.

The plaintiffs argue that the defendant Vicar is barred from setting up the defense
of ownership and/or long and continuous possession of the two lots in question
since this is barred by prior judgment of the Court of Appeals under the principle
of res judicata. Plaintiffs contend that the question of possession and ownership
have already been determined by the Court of Appeals and affirmed by the
Supreme Court.
Defendant Vicar maintains that the principle of res judicata would not prevent
them from litigating the issues of long possession and ownership because the
dispositive portion of the prior merely dismissed their application for registration
and titling of lots 2 and 3. Defendant Vicar contends that only the dispositive
portion of the decision, and not its body, is the controlling pronouncement of the
Court of Appeals
ISSUE: May the decision of the Court of Appeals promulgated a long time ago can
properly be considered res judicata by respondent Court of Appeals in the present
two cases between petitioner and two private respondents?

HELD: Yes. Petitioner was in possession as borrower in commodatum up to 1951,


when it repudiated the trust by declaring the properties in its name for taxation
purposes. When petitioner applied for registration of Lots 2 and 3 in 1962, it had
been in possession in the concept of an owner only for eleven years. Ordinary
acquisitive prescription requires possession for ten years, but always with just
title. Extraordinary acquisitive prescription requires 30 years.

Petitioner did not meet the requirement of 30 years possession for acquisitive
prescription over Lots 2 and 3. Neither did it satisfy the requirement of 10 years
possession for ordinary acquisitive prescription because of the absence of just
title. The appellate court did not believe the findings of the trial court that Lot 2
was acquired from Juan Valdez by purchase and Lot 3 was acquired also by
purchase from Egmidio Octaviano by petitioner Vicar because there was
absolutely no documentary evidence to support the same and the alleged
purchases were never mentioned in the application for registration.

Respondent appellate court did not commit any reversible error, much less grave
abuse of discretion, when it held that the Decision of the Court of Appeals is
governing, under the principle of res judicata, hence the rule, in the present cases
CA-G.R. No. 05148 and CA-G.R. No. 05149. The facts as supported by evidence
established in that decision may no longer be altered.

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