Superiora Locale Dell' Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. vs. Republic of the Philippines

Res judicata does not apply to land registration proceedings where the prior application was dismissed for insufficiency of evidence and no contentious issue essential to the principle was litigated. A curative statute amending the required period of possession for judicial confirmation of imperfect titles applies retroactively to all applications pending as of its effectivity date. The joinder of causes of action for registration of multiple parcels is permissible in the Regional Trial Court provided at least one parcel falls within its jurisdictional amount.

The petitioner, a religious corporation, filed an application for original registration of title over two adjacent lots (Lot No. 1341-A and Lot No. 1341-B) in Tagaytay City. The Office of the Solicitor General opposed the application. It argued that the application for Lot No. 1341-A was barred by res judicata because a prior application for the same lot had been dismissed by the Court of Appeals for failure to prove possession since June 12, 1945, and to prove the land's alienable and disposable character. As for Lot No. 1341-B, the opposition contended the RTC lacked jurisdiction because its assessed value fell below the jurisdictional threshold for RTCs in land registration cases.

• Application: On March 22, 2013, petitioner Superiora Locale Dell' Istituto delle Suore di San Giuseppe del Caburlotto, Inc. filed an application for original registration of title over Lot No. 1341-A (2,876 sq.m.) and Lot No. 1341-B (136 sq.m.) in Tagaytay City. It claimed ownership via a Deed of Extrajudicial Settlement with Absolute Sale and alleged open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier.

• Opposition: The OSG opposed, arguing that as to Lot No. 1341-A, the application was barred by res judicata. A prior application for the same lot (LRC No. 2006-327) had been dismissed by the Court of Appeals in a final decision (CA-G.R. CV No. 92767) dated March 28, 2012, for failure to prove possession since June 12, 1945, and the alienable and disposable nature of the land. As to Lot No. 1341-B, the OSG argued the RTC lacked jurisdiction because its assessed value (₱14,140.00) was below the jurisdictional amount for RTCs.

• RTC Order: The RTC dismissed the application in its Order dated April 11, 2016. It found all elements of res judicata present for Lot No. 1341-A. It dismissed the application for Lot No. 1341-B for lack of jurisdiction, as its assessed value did not exceed ₱100,000.00.

• CA Decision: The CA affirmed the RTC in its Decision dated April 6, 2018. It agreed that res judicata applied to Lot No. 1341-A and that the RTC correctly dismissed Lot No. 1341-B for lack of jurisdiction, ruling that jurisdiction must be based on the individual lot's assessed value, not the aggregate.

• Supreme Court Intervention: The petitioner elevated the case, contending res judicata is inapplicable to land registration dismissals for insufficiency of evidence and that the newly enacted Republic Act No. 11573 should apply.

• Inapplicability of Res Judicata: Petitioner argued that a judgment dismissing an application for land registration for insufficiency of evidence does not constitute res judicata because it does not amount to a conclusive adjudication of ownership.
• Retroactive Application of R.A. No. 11573: Petitioner advanced that R.A. No. 11573, which shortened the required possession period to 20 years, should apply to its pending application, rendering its alleged 65-year possession sufficient.
• Jurisdiction Over Both Lots: Petitioner maintained that the RTC has exclusive original jurisdiction over all land registration applications and that the total assessed value of the lots should determine jurisdiction.

• Application of Res Judicata: The OSG countered that all requisites for res judicata were present: a final judgment on the merits by a court of jurisdiction, with identity of parties, subject matter, and cause of action between the first and second applications.
• Lack of Jurisdiction for Lot 1341-B: The OSG argued that pursuant to Batas Pambansa Blg. 129, as amended, the RTC lacked jurisdiction over Lot No. 1341-B because its individual assessed value was below ₱100,000.00.

• Res Judicata: Whether the principle of res judicata bars the petitioner's second application for registration of Lot No. 1341-A.
• Jurisdiction and Joinder: Whether the RTC has jurisdiction to adjudicate the application for Lot No. 1341-B and whether a joinder of causes of action for both lots is permissible.

• Res Judicata: The principle of res judicata does not apply to bar the application for Lot No. 1341-A. A decree dismissing a registration application for insufficiency of evidence does not constitute a conclusive adjudication of rights between adversarial parties, as no contentious issue essential to res judicata was litigated. Defects in the original application may be remedied by the effluxion of time or a new statute.
• Jurisdiction and Joinder: While the RTC correctly found it lacked jurisdiction over Lot No. 1341-B based on its individual assessed value, a joinder of causes of action is permissible. Pursuant to Section 18 of P.D. No. 1529 and Section 5, Rule 2 of the Rules of Court applied suppletorily, the application for both lots may be heard by the RTC because the application for Lot No. 1341-A falls within its jurisdiction.

• Res Judicata in Land Registration Proceedings — The doctrine of bar by prior judgment does not apply to land registration proceedings where the prior application was dismissed without a hearing or for insufficiency of evidence, and no opposition was filed or contentious issue litigated. Such a dismissal is not a judgment on the merits that conclusively determines ownership.
• Curative Statutes — Statutes intended to cure defects, abridge superfluities, and validate prior invalid acts may be given retroactive effect unless they impair vested rights. R.A. No. 11573, which simplified and harmonized land registration laws by shortening the required possession period, is a curative statute applicable retroactively to pending applications.
• Joinder of Causes of Action in Land Registration — Under Section 18 of P.D. No. 1529 and the Rules of Court, an application may include two or more parcels in the same province or city. Where the causes of action pertain to different jurisdictions, joinder may be allowed in the Regional Trial Court provided one cause of action falls within its jurisdiction.

• "The principle of res judicata does not apply to registration proceedings because there is no conclusive adjudication of rights between the parties or no contentious issue essential to the application of the principle."
• "Defects in the original application may be remedied by the discovery of new evidence or the effluxion of time – the eventual compliance with the requirements of a present statute or the curative effect of a new statute, as in the present case."
• "R.A. No. 11573 is a curative statute... Being a curative statute, R.A. No. 11573 can be retroactively applied."

• Vda. de Santos v. Diaz, 120 Phil. 1477 (1964) — Cited as controlling authority that a dismissal of a registration application for insufficiency of evidence, where no opposition was filed, does not constitute res judicata.
• Republic v. Pasig Rizal, G.R. No. 213207, February 15, 2022 — Followed for its exhaustive discussion that R.A. No. 11573 is a curative statute that applies retroactively to pending land registration applications.
• Filinvest Land, Inc. v. Court of Appeals, 539 Phil. 181 (2006) — Cited for the enumeration of the requisites of res judicata.
• Republic of the Philippines v. T.A.N. Properties, Inc., 578 Phil. 441 (2008) — Its requirements for proving land classification were noted as having been superseded by Section 7 of R.A. No. 11573.

• Section 14(1), Presidential Decree No. 1529 (Property Registration Decree) — As amended by R.A. No. 11573, it now requires possession and occupation under a bona fide claim of ownership for at least 20 years immediately preceding the filing of the application, instead of since June 12, 1945.
• Section 7, Republic Act No. 11573 — Provides that a duly signed certification by a DENR geodetic engineer is sufficient proof that land is alienable and disposable, superseding previous documentary requirements.
• Section 34, Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) — Grants Metropolitan, Municipal, and Municipal Circuit Trial Courts delegated jurisdiction over land registration cases involving lots with no opposition or with a value not exceeding ₱100,000.00.
• Section 18, Presidential Decree No. 1529 — Authorizes an application for registration to include two or more parcels of land belonging to the applicant situated within the same province or city.
• Section 5, Rule 2 of the 1997 Rules of Civil Procedure — Allows the joinder of causes of action, including in the Regional Trial Court where one cause of action falls within its jurisdiction and the venue lies therein.

Gesmundo, C.J., Leonen, SAJ., Hernando, Lazaro-Javier, Inting, M. Lopez, Gaerlan, Rosario, Dimaampao, Marquez, Kho, Jr., and Singh, JJ., concur. Caguioa, J., see Concurring Opinion. Zalameda, J., no part.