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DERLA v. HEIRS OF CATALINA DERLA VDA. DE HIPOLITO

FACTS:

This case involves the dispute over a fishpond area in Tagum, Davao del Norte. Maximino Derla, the deceased father of the petitioners, had originally maintained 20.5 hectares of the fishpond area. A special power of attorney was executed in favor of Catalina Vda. de Hipolito, Derla's cousin, for representation. Furthermore, Derla executed a document transferring his rights in the fishpond area to Hipolito for a sum of money.

Derla filed a complaint to declare the nullity of the transfer of rights in the fishpond permit, but it was dismissed by the court on grounds of prescription and estoppel. Subsequently, Derla filed a complaint against Hipolito for the recovery of the fishpond area, but the complaint was dismissed by the Regional Trial Court (RTC). The decision of the RTC was affirmed by the Court of Appeals, and Derla's petition for review on certiorari was denied by the Supreme Court.

Meanwhile, Hipolito applied for a fishpond permit, and despite opposition from the Municipality of Panabo, the Office of the President ruled in favor of Hipolito and granted the permit. However, later on, the Office of the President revoked its previous ruling and ordered the transfer of the fishpond area to the Municipality of Panabo.

Despite an injunction, the Municipality of Panabo leased portions of the fishpond area to other individuals. In response, Catalina, the widow of Hipolito, filed a petition with the Office of the President for the revival of Hipolito's fishpond sales application, alleging that she was a victim of the Marcos Regime and that the fishpond was taken away from her unjustly.

Catalina's petition was granted by the Office of the President, which directed the Bureau of Fisheries and Aquatic Resources to process and approve the fishpond application of her late husband, Ricardo Hipolito, excluding a strip of one hundred meters from the shoreline. Catalina was also ordered to refund the amount she received as reimbursement from the Municipality of Panabo. The Office of the President held that Ricardo Hipolito had acquired a vested right in the fishpond area and applied the doctrine of res judicata.

ISSUES:

  1. Whether res judicata applies in this case, considering the earlier and final orders of the Office of the President dated February 5, 1974 and July 23, 1974, as well as the Court of Appeals' decision dated July 26, 1977.

  2. Whether res judicata applies to both judicial and quasi-judicial proceedings.

  3. Whether the issue of the authenticity and genuineness of the documents raised by the petitioners had been laid to rest in a previous case.

  4. Whether the material facts presented by the petitioners in their complaint for annulment and cancellation of titles were the same facts determined and resolved in a previous case.

  5. Whether the denial of the motion for reconsideration by Ricardo Hipolito constitutes res judicata against the granting of the sales application of Hipolito.

  6. Whether the documents attached to the motion to dismiss can affect the substantial rights of the petitioner over the subject property.

  7. Whether the doctrine of res judicata applies to this case even if O.P. Case No. 4732 is an administrative case.

  8. Whether the final and executory decision in O.P. Case No. 4732 should be nullified to reinstate the February 11, 1972 decision.

  9. Whether the finality of a previous decision triggers the application of the doctrine of res judicata to bar a subsequent petition.

  10. Whether the petitioners' claim based on the alleged fraudulent transfer of their father's rights is valid.

  11. Whether the RTC's denial of the petition to nullify the transfer of fishpond rights was proper.

RULING:

  1. The Court of Appeals erred in holding that res judicata applies in this case based on the November 11, 1991 resolution of the Office of the President, disregarding the earlier and final orders of the same office dated February 5, 1974 and July 23, 1974, as well as the Court of Appeals' decision dated July 26, 1977.

  2. The Court of Appeals erred in holding that res judicata applies to both judicial and quasi-judicial proceedings. The doctrine of res judicata cannot apply in administrative proceedings, such as the instant case.

  3. The Court of Appeals also erred in holding that the issue of the authenticity and genuineness of the documents had been laid to rest in a previous case. The issue was not resolved in Civil Case No. 5826, as alleged.

  4. Furthermore, the Court of Appeals erred in holding that the material facts presented by the petitioners in their complaint were the same facts determined and resolved in a previous case. The principle of res judicata does not apply in the case at bar.

  5. The Court of Appeals erred in holding that the denial of the motion for reconsideration by Ricardo Hipolito constitutes res judicata against the granting of the sales application. The repetitive protest by the petitioners was not adequately explained in the resolution of November 11, 1991.

  6. The Court of Appeals erred in holding that the documents attached to the motion to dismiss cannot affect the substantial rights of the petitioner over the subject property.

  7. The doctrine of res judicata applies even to administrative proceedings when such proceedings take on an adversary character. In this case, although O.P. Case No. 4732 was initially an administrative case, the fact that the petitioners were able to file motions for reconsideration and were heard by the Office of the President means that the proceedings took on an adversary character. Therefore, the doctrine of res judicata applies.

  8. The final and executory decision in O.P. Case No. 4732 should not be nullified to reinstate the February 11, 1972 decision. The November 11, 1991 decision in O.P. Case No. 4732 is well-written and based on detailed factual antecedents. It revoked or overturned the previous decisions of the Office of the President in 1974. Moreover, the February 11, 1972 decision had already become final and executory before the 1974 decisions were made. Thus, the first judgment to become final and executory, which is the February 11, 1972 decision, should be upheld.

  9. The finality of a previous decision triggers the application of the doctrine of res judicata.

  10. The petitioners' claim based on the alleged fraudulent transfer is barred because it has already been the subject of a separate complaint and ruled upon by the RTC, which held that the action was filed beyond the prescriptive period and that the father was estopped from disputing the authenticity of the transfer.

  11. The RTC's denial of the petition to nullify the transfer of fishpond rights was proper, as it was affirmed by the Court of Appeals and this Court, and the ruling became final.

PRINCIPLES:

  • Vested rights can be acquired by a party who has complied with all the terms and conditions for an award of a certain property.

  • Res judicata prohibits the re-litigation of issues already settled by a final and executory judgment.

  • The doctrine of res judicata requires the concurrence of the following requisites: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be between the first and second actions, identity of parties, subject matter, and cause of action.

  • The statute of limitations sets a time limit on the filing of certain actions, and a claim may be barred if not filed within the prescribed period.

  • Waiver is the intentional relinquishment of a known right, while abandonment is the voluntary relinquishment of property rights.

  • Estoppel precludes a party from alleging or denying a fact in consequence of his own act, omission, or negligence, which precludes another party from proving the truth of such fact by competent evidence.

  • Res Judicata - An existing final judgment or decree rendered on the merits, without fraud or collusion, by a court of competent jurisdiction, upon any matter within its jurisdiction, is conclusive of the rights of the parties or their privies, in all other actions or suits in the same or any other judicial tribunal of concurrent jurisdiction on the points and matters in issue in the first suit.

  • Elements of Res Judicata - (a) The former judgment or order must be final; (b) It must be a judgment or order on the merits; (c) It must have been rendered by a court having jurisdiction over the subject matter and the parties; and (d) There must be, between the first and second actions, identity of parties, subject matter, and cause of action.

  • The test of identity of causes of action lies not in the form of an action but on whether the same evidence would support and establish the former and the present causes of action.

  • The doctrine of res judicata applies not only to judicial or quasi-judicial proceedings but also to administrative proceedings that take on an adversary character.

  • The rule of res judicata applies to the judicial and quasi-judicial acts of public, executive, or administrative officers and boards acting within their jurisdiction.

  • When faced with conflicting final and executory decisions, one option is to determine which judgment came first. The first judgment to become final and executory should be upheld.

  • Doctrine of res judicata: The finality of a previous decision triggers the application of the doctrine of res judicata, which bars the relitigation of claims or issues that have already been finally adjudicated.

  • Prescriptive period: The action to dispute the authenticity of a transfer must be filed within the prescribed period, or else it may be barred.

  • Estoppel: A party may be estopped from disputing the authenticity of a transfer if they used the same document to defend themselves in a previous case.