G.R. No.

210504, January 24, 2018

HEIRS OF ALFONSO YUSINGCO, REPRESENTED BY THEIR ATTORNEY-IN-FACT,

TEODORO K. YUSINGCO, Petitioners, v. AMELITA BUSILAK, COSCA NAVARRO,
FLAVIA CURAYAG AND LIXBERTO1 CASTRO, Respondents.

Facts

The petitioners, heirs of Alfonso Yusingco, filed separate complaints against the
respondents and Reynaldo Peralta for accion publiciana and/or recovery of possession
of three parcels of land located in Surigao City. According to petitioners, they are the
legal owners of the subject properties which they allegedly inherited from Yusingco, but
lost possession of the same during World War II. Petitioners likewise contended that
they discovered that respondents had occupied the properties without their knowledge
nor consent.

In response, respondents argued that they had been in possession of the properties for
over thirty years and that petitioners never possessed or had title to the land.

The MTCC ruled in favor of the petitioners. According to the lower court, petitioners are
the rightful owners of the properties. The decision of MTCC was based on a previous
case where petitioners were declared as co-owners of the properties.

Respondents appealed to the RTC. The latter court affirmed the MTCC's decision.

On appeal, the CA granted respondents' petition for review, setting aside the RTC
decision. The CA held that the previous decisions declaring petitioners as owners did
not bind respondents because they were not parties to those actions. Therefore,
petitioners' actions to recover possession based on those judgments should fail.

Hence, this petition.

Issue

Whether or not the final and executory decisions rendered in a previous accion
reivindicatoria, finding petitioners to be the lawful owners of the subject properties, are
binding upon respondents?
Ruling
The Court rules in the affirmative.
The High Court ruled that the lower courts did not err in ruling that the suits filed by
petitioners are accion reivindicatoria, not accion publiciana, as petitioners seek to
recover possession of the subject lots on the basis of their ownership thereof.
Additionally, it is settled that a judgment directing a party to deliver possession of a
property to another is in personam. In other words, it is conclusive only between the
parties involved and their successors in interest. While actions concerning land are
technically real actions, they are still binding to individuals, but not the general public.
However, there are exceptions where non-parties might be bound by such judgments,
especially in accion interdictal where they act as trespassers, squatters, or
facilitators of the defendant's scheme to evade the judgment.

In this case, the High Court finds no compelling reason to deviate from the findings of
the lower courts, that the respondents are mere intruders or trespassers. Notably, the
evidence presented suggests that the defendants are occupying the properties without
legitimate claim of ownership as required by law. Respondents are merely waiting for
the true owners of the subject properties to prove their ownership. In view thereof, such
an action indicates a lack of rightful possession which disqualifies them from acquiring
ownership through adverse possession. Therefore, the plaintiffs, who have been legally
declared as owners, are entitled to protection against the respondents' unlawful
occupation.