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SPS. RICARDO AND FERMA PORTIC v. ANASTACIA CRISTOBAL

This case has been cited 2 times or more.

2008-10-16
CHICO-NAZARIO, J.
Significantly, suits to quiet title are characterized as proceedings quasi in rem. Technically, they are neither in rem nor in personam. In an action quasi in rem, an individual is named as defendant. However, unlike suits in rem, a quasi in rem judgment is conclusive only between the parties. A proceeding quasi in rem is one brought against persons seeking to subject the property of such persons to the discharge of the claims assailed. [26]
2008-03-28
CHICO-NAZARIO, J.
In an earlier case for quieting of title instituted by the petitioner before the trial court, which reached this Court as G.R. No. 118515,[38] petitioner's ownership and titles to the subject properties had been affirmed with finality, with entry of judgment having been made therein on 15 January 1996. A suit for quieting of title is an action quasi in rem,[39] which is conclusive only to the parties to the suit. It is too glaring to escape our attention that several of the respondents herein were the defendants in the suit for quieting of title before the trial court and the subsequent petitioners in G.R. No. 118515.[40] The finality of the Decision in G.R. No. 118515 is therefore binding upon them.[41] Although the Decision in G.R. No. 118515 is not binding on the other respondents who were not parties thereto, said respondents are still confronted with petitioner's TCTs which they must directly challenge before the appropriate tribunal.