J.M. Tuason & Co., Inc. vs. Mariano

A Torrens title whose validity has been repeatedly upheld in numerous prior decisions can no longer be collaterally attacked at a late hour, the doctrine of stare decisis et non quieta movere and the public policy against repetitive relitigation of settled matters barring any further challenge.

OCT No. 735 covers the Santa Mesa and Diliman Estates of the Tuason mayorazgo or Entail, with areas of 877 (879) and 1,625 hectares, respectively. The title was issued pursuant to a decree dated July 6, 1914 in Case No. 7681 of the Court of Land Registration, registered in the names of defendants Mariano, Teresa, Juan, Demetrio, and Augusto, all surnamed Tuason. Transfer certificates of title derived from OCT No. 735 were issued to J.M. Tuason & Co., Inc., the University of the Philippines, and the National Waterworks and Sewerage Authority (NAWASA), which leased a portion of its land to the Capitol Golf Club. The validity of OCT No. 735 had been the subject of extensive litigation over decades, with the Supreme Court having directly or incidentally sustained the title in numerous cases.

On October 1, 1965, Manuela Aquial and Maria Aquial filed a complaint in forma pauperis in the Court of First Instance of Rizal, Pasig Branch X, docketed as Civil Case No. 8943. They prayed that they be declared the owners of a parcel of land located at Balara, Marikina, Rizal (now Quezon City), bounded on the north by Sapang Mapalad, on the south by the land of Eladio Tiburcio, on the east by Sapang Kolotkolotan, and on the west by Sapang Kuliat. The land, with an area of three hundred eighty-three quinones, was allegedly acquired by their father by means of a Spanish title issued to him on May 10, 1877.

The Aquials alleged that sometime in 1960, or after J.M. Tuason & Co., Inc. had illegally entered upon the land, they discovered that it had been fraudulently or erroneously included in OCT No. 735 of the registry of deeds of Rizal. That title was registered in the names of defendants Mariano, Teresa, Juan, Demetrio, and Augusto, all surnamed Tuason, pursuant to a decree issued on July 6, 1914 in Case No. 7681 of the Court of Land Registration. Transfer certificates of title derived from OCT No. 735 had been issued to J.M. Tuason & Co., Inc., the University of the Philippines, and the National Waterworks and Sewerage Authority (NAWASA), which leased a portion of its land to the Capitol Golf Club. The Aquials prayed that OCT No. 735 and the titles derived therefrom be declared void due to certain irregularities in the land registration proceeding, and they asked for damages.

Defendant J.M. Tuason & Co., Inc. filed a motion to dismiss on the grounds of lack of jurisdiction, improper venue, prescription, laches, and prior judgment. The plaintiffs opposed the motion, and the lower court denied it. The grounds of the motion to dismiss were pleaded as affirmative defenses in the answer of defendants Tuason and J.M. Tuason & Co., Inc., who insisted that a preliminary hearing be held on those defenses. On January 25, 1967, the spouses Jose M. Cordova and Saturnina C. Cordova, who had bought eleven hectares of the disputed land from the Aquials, were allowed to intervene in the case.

On September 5, 1970, the lower court issued an order requiring the parties and the register of deeds of Rizal to produce in court on October 16, 1970 OCT No. 735 and certain transfer certificates of title derived from that basic title. The court later required the production of the plan of the land covered by OCT No. 735, allegedly for the purpose of determining whether the lands claimed by the plaintiffs and the intervenors were included therein. On February 11, 1971, the Tuasons and J.M. Tuason & Co., Inc. filed the instant petition for certiorari and prohibition, praying that the trial court be ordered to dismiss the complaint and enjoined from proceeding in Civil Case No. 8943. After the petitioners filed the proper bond, a writ of preliminary injunction was issued. Respondents Aquial and Cordova answered the petition, and the parties, except the Aquials, filed memoranda in lieu of oral argument.

The supposed irregularities in the land registration proceeding that led to the issuance of the decree upon which OCT No. 735 was based were the same issues raised in Civil Cases Nos. 3621, 3622, and 3623 of the lower court. The 1965 decision of Judge Eulogio Mencias in those cases, which invalidated OCT No. 735, was annexed to the complaint of the Aquials and cited by them to support their action. On appeal to the Supreme Court, that decision was reversed and the validity of OCT No. 735 and derivative titles was once more upheld in Benin vs. Tuason (L-26127), Alcantara vs. Tuason (L-26128), and Pili vs. Tuason (L-26129), all decided on June 28, 1974. That ruling was subsequently applied in Mara, Inc. vs. Estrella (L-40511, July 25, 1975).

• Affirmative Defenses: Petitioners argued that the complaint should be dismissed on the grounds of lack of jurisdiction, improper venue, prescription, laches, and prior judgment, these having been pleaded as affirmative defenses after their motion to dismiss was denied.
• Stare Decisis: Petitioners maintained that OCT No. 735 and the titles derived therefrom can no longer be questioned at this late hour, the same issues regarding irregularities in the land registration proceeding having been raised and adjudicated in prior cases, culminating in the Supreme Court's reversal of the lower court's invalidation of OCT No. 735 in the Benin, Alcantara, and Pili cases.

• Fraudulent Inclusion: Respondents Aquial alleged that their father acquired the disputed land by means of a Spanish title issued on May 10, 1877, and that the land was fraudulently or erroneously included in OCT No. 735.
• Invalidity of OCT No. 735: Respondents argued that OCT No. 735 and the titles derived therefrom should be declared void due to certain irregularities in the land registration proceeding, citing the 1965 decision of Judge Mencias in Civil Cases Nos. 3621, 3622, and 3623, which had invalidated OCT No. 735, as support for their action.

• Collateral Attack on OCT No. 735: Whether OCT No. 735 and the titles derived therefrom can be questioned at this late hour by respondents Aquial and Cordova, given that the same issues regarding irregularities in the land registration proceeding had been previously adjudicated and settled.

• Collateral Attack on OCT No. 735: No. OCT No. 735 and derivative titles can no longer be collaterally attacked, the doctrine of stare decisis et non quieta movere and public policy against repetitive relitigation of settled matters barring any further challenge to the title's validity.

• Collateral Attack on OCT No. 735: The supposed irregularities in the land registration proceeding that led to the issuance of the decree upon which OCT No. 735 was based are the same issues raised in Civil Cases Nos. 3621, 3622, and 3623 of the lower court. The 1965 decision of Judge Mencias invalidating OCT No. 735 was reversed on appeal to the Supreme Court in Benin vs. Tuason (L-26127), Alcantara vs. Tuason (L-26128), and Pili vs. Tuason (L-26129), all decided on June 28, 1974, where the validity of OCT No. 735 and derivative titles was once more upheld. That ruling was subsequently applied in Mara, Inc. vs. Estrella (L-40511, July 25, 1975). The Court further noted that the ruling in the Benin, Alcantara, and Pili cases was simply a reiteration or confirmation of holdings in numerous prior cases directly or incidentally sustaining OCT No. 735, spanning from Bank of the P.I. vs. Acuna (59 Phil. 183) through Varsity Hills, Inc. vs. Navarro (L-30889, February 29, 1972) and People's Homesite and Housing Corporation vs. Mencias (L-24114, August 16, 1967). Applying the governing principle of stare decisis et non quieta movere — follow past precedents and do not disturb what has been settled — the Court concluded that respondents Aquial and Cordova cannot maintain their action without eroding the long-settled holding that OCT No. 735 is valid and no longer open to attack. The Court further invoked the maxim Interest rei publicae ut finis sit litium, emphasizing that it is against public policy that matters already decided on the merits be relitigated again and again, consuming the Court's time and energies at the expense of other litigants.

• Stare decisis et non quieta movere — The doctrine that courts should follow past precedents and not disturb what has been settled. The Court applied this principle to bar respondents from relitigating the validity of OCT No. 735, which had been repeatedly upheld in numerous prior decisions. Where a legal question has been settled by repeated adjudications, the doctrine operates to prevent erosion of established holdings and to conserve judicial resources.

• Interest rei publicae ut finis sit litium — The maxim that it is in the public interest that there be an end to litigation. The Court invoked this principle to emphasize that it is against public policy for matters already decided on the merits to be relitigated again and again, consuming the Court's time and energies at the expense of other litigants.

• Indefeasibility of Torrens Title — A Torrens title that has been judicially upheld and has become final can no longer be collaterally attacked. The Court reinforced the principle that OCT No. 735, having been sustained in numerous cases, is valid and no longer open to attack, and derivative titles issued thereunder enjoy the same protection.

• "Considering the governing principle of stare decisis et non quieta movere (follow past precedents and do not disturb what has been settled), it becomes evident that respondents Aquial and Cordova cannot maintain their action in Civil Case No. 8943 without eroding the long settled holding of the courts that OCT No. 735 is valid and no longer open to attack." — This passage states the ratio decidendi of the decision, applying the doctrine of stare decisis to bar collateral attack on a title whose validity has been repeatedly affirmed.

• "It is against public policy that matters already decided on the merits be relitigated again and again, consuming the Court's time and energies at the expense of other litigants: Interest rei publicae ut finis sit litium." — This passage articulates the public policy rationale underlying the dismissal, invoking the Latin maxim that there must be an end to litigation, and is frequently cited in subsequent jurisprudence on repetitive relitigation.

• Benin vs. Tuason, L-26127; Alcantara vs. Tuason, L-26128; Pili vs. Tuason, L-26129 (June 28, 1974, 57 SCRA 531) — Controlling precedent. These consolidated cases reversed the 1965 lower court decision invalidating OCT No. 735 and once more upheld the validity of the title and derivative titles. The Court treated these as the most recent and direct affirmance of OCT No. 735's validity, applying their ruling to dismiss the respondents' complaint.

• Mara, Inc. vs. Estrella, L-40511 (July 25, 1975, 65 SCRA 471) — Followed. The Court cited this case as a subsequent application of the ruling in the Benin, Alcantara, and Pili cases, reinforcing the validity of OCT No. 735.

• Varsity Hills, Inc. vs. Navarro, L-30889 (February 29, 1972, 43 SCRA 503) — Followed and quoted. The Court cited this case both as one of the prior decisions sustaining OCT No. 735 and as the source of the quoted maxim on public policy against repetitive relitigation.

• People's Homesite and Housing Corporation vs. Mencias, L-24114 (August 16, 1967, 20 SCRA 1031) — Followed. Cited as one of the prior cases directly or incidentally sustaining OCT No. 735.

• Barretto vs. Tuason, 50 Phil. 888 — Cited as an early case involving OCT No. 735 and the Santa Mesa and Diliman Estates of the Tuason mayorazgo, providing historical context for the long-running dispute.

Barredo (Acting Chairman), Antonio, Concepcion, Jr., and Santos, JJ., concurred. Fernando, J., did not participate.