G.R. No. 171717 ; December 15, 2010
RAMON B. BRITO, SR., Petitioner, vs. SEVERINO D. DIANALA, et al., Respondents.

FACTS

The dispute involves a parcel of land originally owned by the spouses Esteban Dichimo and Eufemia Dianala. Petitioner Ramon Brito, Sr., representing the heirs of Vicente Dichimo (a son from Esteban’s marriage to Eufemia), was a plaintiff in an earlier case (Civil Case No. 12887) for recovery of possession against a third party. That case concluded with a compromise agreement, resulting in the issuance of a title in the names of petitioner’s co-heirs. Respondents, claiming to be heirs of Esteban from a prior marriage to Francisca Dumalagan, filed an Answer-in-Intervention in that prior case, asserting their own hereditary rights. However, the trial court dismissed their intervention for failure to secure counsel.
Subsequently, petitioner filed a new complaint for recovery of possession against respondents (Civil Case No. 548-C). Respondents, in turn, filed a Complaint for Reconveyance and Damages against petitioner (Civil Case No. 588-C). The trial court consolidated the cases but dismissed both via Joint Orders. It dismissed the reconveyance case (588-C) for lack of jurisdiction, reasoning that granting the relief sought would effectively annul the final judgment in the prior case (12887). Respondents appealed this dismissal to the Court of Appeals.

ISSUE

Whether the Regional Trial Court correctly dismissed the Complaint for Reconveyance for lack of jurisdiction on the ground that it would amount to an annulment of a final judgment.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The RTC had jurisdiction over the reconveyance case. The Court clarified that an action for reconveyance is a remedy available to a legal owner against a registered owner when the property has been wrongfully registered in the latter’s name. Such an action does not seek to nullify a prior final and executory judgment but aims to correct the registered ownership by compelling the defendant to transfer the property to its rightful owner.
The Court held that respondents were not parties to the prior compromise judgment in Civil Case No. 12887. Their Answer-in-Intervention had been dismissed; thus, they were never legally recognized as parties to that suit. Consequently, they were not bound by its judgment. Their reconveyance action, which was based on their claim of being compulsory heirs from Esteban’s first marriage, was a separate and distinct claim of ownership. Allowing it to proceed would not annul the prior judgment but would merely determine the better right of ownership between the present contending parties. Dismissing their suit would deprive them of their day in court and potentially of their property without due process. The case was remanded to the trial court for a hearing on the merits.