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L-55152
-vs-
Up for resolution is a petition for certiorari with prayer for a temporary restraining order of
two issued orders by respondent Judge in Land Registration Case.
Held:
The Court held that the principle of res judicata applies in the instant case and moreover
sited the requisites of the principle: (a) the former judgment must be final, (b) it must have been'
rendered by a court having jurisdiction of the subject matter and of the parties, (c) it must be a
judgment on the merits and (d) there must be between the first and second actions identity of
parties, of subject matter and of cause of action.
These aforementioned requisites are present in the case at bar. Between the
registration case and the prior civil action for recovery of property, there is the existence of
the (1) identity of parties; (2) subject matter; and (3) cause of action and the decision
rendered by the Court of Appeals which had jurisdiction over the subject matter and the
parties, is a final judgment on the merits.
The lands sought to be recovered by petitioners are the same parcels of land being
sought to be registered in Cayaba and Noriega's names . While the complaint in the first action
is captioned for recovery of possession, the allegations and the prayer for relief therein raise the
issue of ownership. In effect, it is in the nature of an accion reinvidicatoria. Between the two cases
there is identity of causes of action because in accion reinvidicatoria, possession is sought on the
basis of ownership and the same is true in registration cases. Registration of title in one's name is
based on ownership. In both cases, the plaintiff and the applicant seek to exclude other persons
from ownership of the land in question. The only difference is that in the former case, the
exclusion is directed against particular persons, while in the latter proceedings, the exclusion is
directed against the whole world. Nonetheless, the cause of action remains the same. It does not
matter that a court of general jurisdiction decided the first case, while the second case is being
heard by one of a limited jurisdiction, such as a registration court. It is enough that the court,
which decided the first case on the merits, had validly acquired jurisdiction over the subject
matter and the parties. That both courts should have equal jurisdiction is not a requisite of res
judicata. Petition dismissed.