SPS. MARIO OCAMPO v. HEIRS OF BERNARDINO U. DIONISIO

FACTS:

The case involves a complaint for recovery of possession filed by the heirs of Bernardino Dionisio against Mario and Carmelita Ocampo. The respondents claimed ownership of a parcel of land covered by Original Certificate of Title (OCT) No. M-4559, which they acquired from Dionisio. They alleged that Mario constructed a piggery on a portion of the subject property without their consent. The petitioners argued that the subject property is owned by Carmelita and that they have been in possession since 1969. They also contended that the respondents' complaint is barred by res judicata due to the finality of a previous decision in a forcible entry case. The MTC dismissed the complaint on the ground of res judicata. The RTC, however, reversed the decision and declared the respondents entitled to possession. The CA affirmed the RTC's decision, finding that there is no identity of cause of action between the forcible entry case and the recovery of possession case. The CA also held that the respondents have established their ownership and that laches does not bar their cause of action. The petitioners filed a petition for review with the Supreme Court seeking to annul the CA's decision.

ISSUES:

  1. Whether the finality of the decision in the forcible entry case constitutes res judicata.

  2. Whether the respondents were able to establish their ownership of the subject property.

  3. Whether the respondents' cause of action is already barred by laches.

  4. Whether a judgment rendered in a forcible entry case bars an action between the same parties respecting title or ownership.

  5. Whether the respondents have a superior right and ownership over the subject property.

  6. Whether the respondents' right to recover possession of the subject property is barred by laches.

RULING:

  1. The petition is denied.

  2. The ruling is that a judgment rendered in a forcible entry case will not bar an action between the same parties respecting title or ownership. There is no identity of causes of action between a forcible entry case and an accion reinvindicatoria. The determination in the forcible entry case is conclusive only as to the possession and does not affect the ownership of the land.

  3. The ruling is that the respondents have a superior right and ownership over the subject property. They were able to prove their ownership through the OCT registered in the name of their predecessor-in-interest. A certificate of title is evidence of indefeasible ownership and entitlement to possession.

  4. The ruling is that the respondents' right to recover possession of the subject property is not barred by laches. The right to recover possession from any person illegally occupying the property is imprescriptible and not subject to prescription or adverse possession under the Torrens system.

PRINCIPLES:

  • The doctrine of res judicata, under Section 47, Rule 39 of the Rules of Court, includes two concepts: bar by former judgment and conclusiveness of judgment.

  • For the bar by former judgment to apply, there must be finality of the former judgment, jurisdiction of the court which rendered it over the subject matter and the parties, a judgment on the merits, and identity of parties, subject matter, and causes of action between the first and second actions.

  • In cases of forcible entry, the issue is only possession in fact or physical possession of the property, independently of any claim of ownership.

  • Recovery of possession cases involve the issue of ownership and the right to possess the property as an attribute of ownership.

  • A determination in a forcible entry case is limited to the issue of actual prior possession, regardless of ownership.

  • A judgment in a forcible entry case does not bar an action for title or ownership between the same parties.

  • A certificate of title serves as evidence of indefeasible ownership and entitlement to possession.

  • Prescription and laches do not apply to registered land covered by the Torrens system.