G.R. No. 153914 ; July 31, 2007
FELIPE REGIS, JR., Petitioner, vs. THE HON. COURT OF APPEALS and AGAPITO GARCIA, Respondents.

FACTS

This case originated from two ejectment suits between the same parties over a parcel of land in Iligan City. The first, Civil Case No. II-236, was a forcible entry complaint filed by the parents of petitioner Felipe Regis, Jr. against respondent Agapito Garcia. In a 1989 Decision, the Municipal Trial Court in Cities (MTCC) dismissed the case, finding Garcia to be the possessor and owner of a 200-square-meter lot since 1947, which was later awarded to him via a Miscellaneous Sales Application. This decision became final and executory as no appeal was taken.
The second case, Civil Case No. 1-429, was an ejectment complaint filed by Garcia against Regis. In 1999, the MTCC dismissed this complaint, ruling Garcia failed to prove his prior physical possession. On appeal, the Regional Trial Court (RTC) reversed the MTCC, ordering Regis to vacate. The RTC heavily relied on the final and executory 1989 MTCC decision in the first case, which established Garcia’s prior possession. The Court of Appeals affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the RTC decision which applied the principle of res judicata based on the final judgment in the first ejectment case.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal logic rests on the conclusive effect of a final judgment under the principle of res judicata. The 1989 MTCC decision in Civil Case No. II-236, which became final, contained definitive findings that Garcia was in possession of the 200-square-meter lot since 1946/1947 and that the contested 40-square-meter portion was within this lot. These findings on the fact of prior possession are conclusive upon the parties and their privies.
In the second ejectment case, Regis, being a privy to his parents who were the plaintiffs in the first case, is bound by the earlier final judgment. The RTC and the Court of Appeals correctly held that Regis was barred from re-litigating the issue of prior physical possession, which had already been settled with finality. An ejectment case primarily determines who is entitled to physical possession based on prior possession, not ownership. The final finding in the first case that Garcia had prior possession is thus binding in the subsequent suit involving the same parties and the same property. The courts did not err in applying res judicata to uphold Garcia’s superior right of possession.