Abalos vs. Court of Appeals, 321 SCRA 466

Abalos vs.
Court of Appeals, 321 SCRA 466
Doctrine:
Documents as evidence, as defined in Section 2 of Rule 130, encompass any material containing
letters, words, numbers, figures, symbols, or other modes of written expression offered as proof of
their contents. In the context of land registration proceedings, documents such as deeds of sale serve as
crucial evidence in establishing ownership rights over the land in question.
In land registration proceedings, it is expected of the applicant to adduce evidence, testimonial and
documentary, and for the oppositor to adduce proof of equal, if not more, evidentiary weight to
defeat the claim of ownership. The purpose of the applicant is to prove that he has absolute or
registerable title over the property applied for.
Facts:
Spouses Braulio and Aquilina Abalos applied for registration of title over a parcel of land in Lingayen,
Pangasinan, with a portion owned by Roman Soriano.
Roman Soriano opposed the application, claiming a larger share of ownership than stated by the Abalos
spouses.
The land was originally owned by Adriano Soriano, and upon his death, it was inherited by his children,
including Roman Soriano.
A deed of extrajudicial partition was executed among Adriano's heirs, dividing the property into
northern and southern portions, with Roman Soriano owning a one-fourth share of the southern
portion.
In 1971, the Abalos spouses purchased shares of the property from some of Adriano's heirs, including
Roman Soriano, who did not object to the sale at the time.
The land registration court granted the Abalos spouses' application for registration, confirming their
ownership based on valid deeds of sale.
Roman Soriano appealed the decision, but both the appellate court and the Supreme Court affirmed the
land registration court's ruling.
Subsequently, Roman Soriano filed a complaint seeking the annulment of documents and ownership
against the Abalos spouses in a separate civil case.
The trial court initially dismissed the complaint, but later reconsidered its decision and ordered the
Abalos spouses to file their answer.
The Abalos spouses filed a petition for certiorari and prohibition before the Court of Appeals, alleging
that the trial court's refusal to dismiss the complaint amounted to lack of jurisdiction.
The Court of Appeals dismissed the petition, ruling that the land registration court had limited
jurisdiction and could not pass upon questions regarding the validity of contracts affecting the disputed
property.
The Abalos spouses appealed the decision of the Court of Appeals to the Supreme Court.
Issue:
Whether or not the subsequent action for annulment of documents and ownership should be dismissed
based on the principle of res judicata.
Ruling:
The Supreme Court reversed the decision of the Court of Appeals and ordered the trial court to dismiss
the complaint.
A land registration court has the authority to determine conflicting claims of ownership over the land
sought to be registered, as long as the parties agree or acquiesce in submitting the issue for
determination by the court.
In this case, the issue of ownership was fully litigated before the land registration court, with both
parties presenting evidence to support their claims.
The land registration court found that the Abalos spouses obtained ownership of the land through
valid deeds of sale, and this finding was affirmed by the appellate court and the Supreme Court in the
previous land registration case.
Therefore, the principle of res judicata applies, and the subsequent action for annulment of
documents and ownership should be dismissed.
The land registration court's jurisdiction is not limited to purely registration matters, but also extends to
issues of ownership that are material and germane to the registration proceedings.
A land registration proceeding is an action in rem, binding on the whole world, and the question of
ownership is often evidenced by documents.
Therefore, the land registration court must have jurisdiction to determine the validity of the
documents relied upon by the parties.
Disposition:
WHEREFORE, the petition is GRANTED and the assailed decision of the

respondent court is hereby REVERSED and SET ASIDE. The Regional Trial
Court, Branch 37, of Lingayen, Pangasinan, is further ordered to dismiss Civil
Case No. 15958 with costs against plaintiff therein. Costs against private
respondents in this instance.

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Abalos vs.

Court of Appeals, 321 SCRA 466

WHEREFORE, the petition is GRANTED and the assailed decision of the

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