LAURA ALVAREZ v. IAC

FACTS:

The case involves two parcels of land, Lot 773-A and Lot 773-B, originally known as Lot 773, registered in the name of the heirs of Aniceto Yanes. Jesus, one of Aniceto's children, discovered after World War II that Fortunato Santiago, Fuentebella, and Alvarez were in possession of Lot 773. Santiago was issued titles for Lot 773-A and a bigger portion of Lot 773. He eventually sold the lots to Fuentebella, who sold them to Alvarez. In 1960, Teodora and the children of Rufino filed a complaint against Santiago, Fuentebella, Alvarez, and the Register of Deeds for the return of ownership and possession of Lots 773 and 823. During the case, Alvarez sold Lots 773-A and 773-B to Siason. A decision was eventually rendered, ordering Alvarez to reconvey the lots to the plaintiffs.

In a subsequent execution of the decision in Civil Case No. 5022, the sheriff reported that Lot 773 had been subdivided into Lots 773-A and 773-B, which were in the name of Siason. Siason argued that he was not a party to the writ of execution, therefore, Lot 773 could not be delivered to the plaintiffs. The Yaneses filed a petition for a new certificate of title and a declaration of nullity of the titles issued to Alvarez. Siason claimed to have purchased the lots in good faith without knowledge of any lien or encumbrances. The cadastral court nullified its previous order requiring Siason to surrender the titles. The Yaneses filed a motion for an alias writ of execution but Siason opposed it, arguing that the judgment could not be enforced against him as he was not a party to the case. The Yaneses subsequently filed an action for the recovery of the land and damages against Siason and other defendants. In his answer, Siason claimed that the validity of his titles had been settled in a previous order. The Alvarezes argued in their answer that the Yaneses' cause of action was barred by res judicata, statute of limitation, and estoppel. The lower court eventually found that Siason purchased the properties in question.

ISSUES:

  1. Whether the defense of prescription and estoppel had been timely and properly invoked and raised by the petitioners in the lower court.

  2. Whether the cause and/or causes of action of the private respondents are forever barred by statute of limitation and/or prescription of action and estoppel.

  3. Whether the late Rosendo Alvarez became a party to the waiver in Civil Case No. 8474.

  4. Whether the liabilities of Rosendo Alvarez arising from the sale of the lots could be legally passed to the petitioners.

  5. Whether the rights of the Yaneses to the properties have been finally adjudicated in a prior case.

  6. Whether the present case can be reopened to consider the defenses of prescription and estoppel.

  7. Whether the liability arising from the sale of the properties should be the sole liability of the late Rosendo Alvarez or his estate.

  8. Whether the petitioners are liable for the damages claimed arising from the transaction related to the inherited property.

  9. Whether the petitioners are liable to the extent of the value of their inheritance only.

  10. Whether there are other properties left by the deceased that are sufficient to cover the amount adjudged in favor of the private respondents.

RULING:

  1. The Court of Appeals ruled that the defense of prescription and estoppel had not been timely and properly invoked by the petitioners. The cause of action of the private respondents was also not forever barred by statute of limitation, prescription of action, or estoppel. The court also held that the liabilities of Rosendo Alvarez arising from the sale of the lots could not be legally passed to the petitioners.

  2. Yes, the rights of the Yaneses to the properties have been finally adjudicated in a prior case. The court ruled that the judgment in Civil Case No. 5022, which declared the Yaneses as the rightful owners, is final and conclusive upon the parties.

  3. No, the present case cannot be reopened to consider the defenses of prescription and estoppel. The court held that the petitioners should have appealed the prior case if they wished to raise these defenses. Since they failed to do so, they have foreclosed their rights and cannot now complain in another case to defeat the enforcement of the final judgment.

  4. The liability arising from the sale of the properties should not be the sole liability of the late Rosendo Alvarez or his estate. The court ruled that the rights and obligations of the deceased are transmissible to his legitimate children and heirs. Therefore, the petitioners, being the heirs of Rosendo Alvarez, cannot escape the legal consequences of their father's transaction. They are jointly liable for the damages claimed by the Yaneses.

  5. Yes, the petitioners are liable for the damages claimed arising from the transaction related to the inherited property.

  6. Yes, the petitioners are liable to the extent of the value of their inheritance only.

  7. Yes, there are other properties left by the deceased that are sufficient to cover the amount adjudged in favor of the private respondents.

PRINCIPLES:

  • A decision of a court of competent jurisdiction that has become final and executory is the law of the case between the parties and cannot be reviewed or reversed by another court.

  • The defense of prescription and estoppel must be timely and properly invoked in court to be considered valid.

  • Liabilities arising from a contract or transaction cannot be passed on to another person by operation of law without violation of law and due process.

  • Finality of Judgment - A final judgment of a competent court is conclusive upon the parties and those in privity with them in law or estate.

  • Limitation on Access to Courts - While access to courts is guaranteed, there must be a limit to it. Once a litigant's right has been adjudicated in a valid final judgment, they should not be granted an unbridled license to return for another try.

  • Remedies in Case of Wrongful Registration - The sole remedy of a landowner whose property has been wrongfully or erroneously registered in another's name is to bring an ordinary action for reconveyance or, if the property has passed into the hands of an innocent purchaser for value, for damages.

  • Transmissibility of Rights and Obligations - The rights and obligations of a deceased party are transmissible to their legitimate children and heirs, unless the nature of the rights and obligations or a stipulation or provision of law provides otherwise.

  • Hereditary assets are always liable in their totality for the payment of the debts of the estate.

  • Petitioners' liability is limited to the value of their inheritance.

  • The existence of other properties left by the deceased which are sufficient to cover the adjudged amount may be considered as a basis for affirming the findings and conclusions of the Court of Appeals.