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HEIRS OF ALFONSO YUSINGCO v. AMELITA BUSILAK

FACTS:

The petitioners in this case filed separate complaints for accion publiciana and/or recovery of possession against the respondents and Reynaldo Peralta. The complaints were consolidated and filed with the Municipal Trial Court in Cities (MTCC) of Surigao City. The petitioners claimed ownership of three parcels of land, which they inherited from their predecessor-in-interest, Alfonso Yusingco. They alleged that they were in possession of the properties prior to and during the Second World War but lost possession during the war. After the war, they discovered that the properties were occupied by several persons, including the respondents. During the pendency of the cases they initially filed, the respondents entered different portions of the properties without the knowledge and consent of the plaintiffs. The petitioners demanded that the respondents vacate the properties, but they refused. The MTCC rendered a judgment in favor of the petitioners, ordering the respondents to vacate the premises occupied by them and pay compensation for the use of the properties. The respondents filed an appeal with the Regional Trial Court (RTC), which affirmed the judgment with modification as to the judgment against the respondents who did not file an appeal. The respondents then filed a petition for review before the Court of Appeals, which granted the petition and dismissed the consolidated cases for lack of merit.

ISSUES:

  1. Whether the final and executory decisions rendered in a previous accion reivindicatoria are binding upon respondents.

  2. Whether respondents have a better right of possession over the subject matter property despite the rulings in the prior judgments.

  3. Whether the judgments on a previous case for accion reivindicatoria, which was filed by petitioners against persons other than respondents, are binding upon the respondents.

  4. Whether respondents, who are mere intruders or trespassers, have the right to possess the subject lots.

RULING:

  1. The final and executory decisions rendered in a previous accion reivindicatoria are binding upon respondents. The Court ruled that the judgments in the previous accion reivindicatoria declared petitioners as the lawful owners of the subject properties, and these judgments are binding upon respondents. The judgments in an accion reivindicatoria determine the ownership of the property and award the possession of the property to the lawful owner.

  2. The judgments on a previous case for accion reivindicatoria are binding upon the respondents. A judgment directing a party to deliver possession of a property to another is in personam, and it is conclusive only between the parties and their successors in interest. However, even a non-party may be bound by the judgment in an ejectment suit if they fall under certain categories, such as being a trespasser or squatter occupying the property to frustrate the judgment. In this case, the respondents are mere intruders or trespassers without a right to possess the subject lots, and therefore they are bound by the previous judgments.

  3. The respondents, being mere intruders or trespassers, do not have the right to possess the subject lots. Their physical possession of the premises was not under claim of ownership or in the concept of an owner, and they did not apply for any legal modes of acquiring land from the public domain. Their possession cannot ripen into ownership by prescription. As owners of the land, the petitioners are entitled to legal protection and the right to possess the subject lots.

PRINCIPLES:

  • Accion reivindicatoria is an action to recover ownership and possession of a parcel of land. The judgment in an accion reivindicatoria determines the ownership of the property and awards the possession of the property to the lawful owner.

  • The final and executory decisions in a previous accion reivindicatoria are binding upon the parties properly impleaded in the said action.

  • A judgment directing a party to deliver possession of a property to another is in personam and is binding only upon the parties properly impleaded and duly heard or given an opportunity to be heard.

  • Even a non-party may be bound by the judgment in an ejectment suit if they fall under certain categories, such as being a trespasser or squatter occupying the property to frustrate the judgment.

  • A person who is occupying a property as a mere intruder or trespasser without a right of possession cannot acquire ownership by prescription.