DE KNECHT VS. COURT OF APPEALS
Facts:
The instant case is an unending sequel to several suits commenced almost
twenty years ago involving a parcel of land located at the corner of the south
end of EDSA and F.B. Harrison in Pasay City. The land was owned by petitioners
Cristina de Knecht and her son, Rene Knecht.
On the land, the Knechts constructed eight houses, leased out the seven
and occupied one of them as their residence. In 1979, the government filed for
the expropriation of Knechts’ property.
The government wanted to use the land for the completion of the Manila
Flood Control and Drainage Project and the extension of the EDSA towards Roxas
Boulevard. In 1982, the City Treasurer of Pasay discovered that the Knechts
failed to pay real estate taxes on the property from 1980 to 1982. As a
consequence of this deficiency, the City Treasurer sold the property at public
auction for the same amount of their deficiency taxes. The highest bidders were
respondent Spouses Anastacio and Felisa Babiera (the Babieras) and respondent
Spouses Alejandro and Flor Sangalang (the Sangalangs). Subsequently, Sangalang
and Babiera sold the land to respondent Salem Investment Corporation. On
February 17, 1983, the Batasang Pambansa passed B.P. Blg. 340 authorizing the
national government to expropriate certain properties in Pasay City for the
EDSA Extension. The property of the Knechts was part of those expropriated
under B.P. Blg. 340. The government gave out just compensation for the lands expropriated
under B.P. Blg. 340. Salem was included and received partial payment. Seven of the
eight houses of the Knechts were demolished and the government took possession
of the portion of land on which the houses stood. Since the Knechts refused to
vacate their one remaining house, Salem filed a case against them for unlawful
detainer. As defense, the Knechts claimed ownership of the land and building.
The Municipal Trial Court however ordered the Knechts' ejectment thus their
residence was demolished. The Knechts continuously claimed ownership of the
property and allege that they must be given just compensation.
Issue: Whether or not Knechts are the lawful owners of the land at subject.
Held:
The Supreme Court held that the Knechts were not the owners anymore of the
said land. The Knechts' right to the land had been foreclosed after they failed
to redeem it one year after the sale at public auction. Since the petitions
questioning the order of dismissal were likewise dismissed by the Court of
Appeals and this Court, the order of dismissal became final and res judicata on
the issue of ownership of the land. Petitioners contended that they did not
receive notice of their tax delinquency. Neither did they receive notice of the
auction sale. However, this question has been previously raised in the cases
which have been already set aside. The court is not a trier of facts. Res
judicata has already set it. The Knechts therefore are not the lawful owners of
the land and are not any longer accountable for just compensation given by the
government.
Note: Res judicata is a ground for dismissal of an
action. It is a rule that precludes parties from relitigating Issue actually
litigated and determined by a prior and final judgment. It pervades every well-regulated
system of jurisprudence, and is based upon two grounds embodied in various maxims
of the common law one, public policy and
necessity, that there should be a limit to litigation; and another, the
individual should not be vexed twice for the same cause. When a right of fact
has been judicially tried and determined by a court of competent jurisdiction,
or an opportunity for such trial has been given, the judgment of the court, so
long as it remains unreversed, should be conclusive upon the parties and those
in privity with them in law or estate. To follow a contrary doctrine would
subject the public peace and quiet to the will and neglect of individuals and
prefer the gratification of the litigious disposition of the parties to the
preservation of the public tranquility.Res judicata applies when: (1) the
former judgment or order is final; (2) the judgment or order is one on the
merits; (3) it was rendered by a court having jurisdiction over the subject
matter and the parties; (4) there is between the first and second actions, identity of parties, of subject
matter and of cause of action.