[DEGAYO v.

MAGBANUA-DINGLASAN] (2015) progressively decreased in size while the banks adjacent

to Lot No. 861 gradually increased in land area.
[Brion, J.]
Degayo: believed that the area was an accretion to Lot
TOPIC Judicial Notice - When Hearing No. 861. As a result, her tenants, commenced cultivating
Necessary and tilling that disputed area with corn and tobacco. The
DOCTRINE A court will take judicial notice of its own area allegedly added to Lot No. 861 contains 52,528 sqm.
acts and records in the same case, of
facts established in prior proceedings in Respondents: argued that the disputed property was an
the same case, of the authenticity of its abandoned riverbed, which should rightfully belong to
own records of another case between them to compensate for the portion of Lot No. 7328, over
the same parties, of the files of related which the Jalaud River presently runs.
cases in the same court, and of public
records on file in the same court. In The respondents filed a complaint for ownership and
addition judicial notice will be taken of damages against the tenants (Civil Case No. 16047).
the record, pleadings or judgment of a Degayo sought to intervene but her motion was denied.
case in another court between the same
parties or involving one of the same Notably, Degayo never bothered to question the
parties, as well as of the record of interlocutory order denying her motion for intervention by
another case between different parties filing a petition for certiorari. Instead, Degayo initiated Civil
in the same court. Case No. 18328 against the respondents for declaration
EVIDENCE Degayo’s testimony as witness; of ownership with damages. In her complaint, Degayo
Quitclaim Deed alleged to have acquired Lot No. 861 by inheritance by
virtue of a Quitclaim Deed and that she had been in
I. FACTS possession of that land since 1954. She likewise stressed
that the area in dispute was an accretion to Lot No. 861.
There are 2 civil cases for ownership and damages
between conflicting claimants over a parcel of land Meanwhile, notwithstanding the previous denial of her
located on the northeastern bank of Jalaud River. motion to intervene, Degayo was able to participate in the
proceedings therein as a witness for the defense. In
The respondents initiated the first civil case against the particular, during her direct examination, Degayo testified
tenants (tenants) of Lot No. 861. Degayo initiated the on the same matters and raised the same arguments she
second civil case. alleged in her complaint (that she acquired Lot No. 861 by
inheritance by virtue of a Quitclaim Deed; that she had
Lot No. 861 is registered in the name of Degayo’s
been in possession of that land since 1954; and that the
deceased parents, spouses Marcelo Olmo and Rosalia
area in dispute was an accretion to Lot No. 861)
Labana. Lot No. 861 used to be bounded on the
southwest by the Jalaud River that serves to separate RTC on the civil case filed by the respondents (Civil
Dingle from Pototan Iloilo. On the other side of Jalaud Case No. 16047): rendered its decision in favor of the
River, opposite Lot No. 861, lies Lot No. 7328 of the respondents. The tenants promptly filed an appeal but
Cadastre of Pototan collectively owned by the they failed to file an appeal brief, resulting to a dismissal
respondents. The Jalaud River, which separates these of their appeal. The decision became final and executory.
parcels of land, thus flows along the northeast side of Lot
861 and the southwest side of Lot No. 7328. RTC on the case for the declaration of ownership filed
by Degayo (Civil Case No. 18328): court found in favor
Sometime in the 1970’s the Jalauad River steadily of Degayo and declared the property in question as an
changed its course and moved southwards towards the accretion to Lot No. 861. The respondents filed a motion
banks of Pototan, where Lot No. 7328 lies, leaving its old for reconsideration but their motion was denied.
riverbed dry. Eventually, the course of the Jalaud River
encroached on Lot No. 7328. As a result, Lot No. 7328
CA: Reversed RTC (on the case for the declaration of previous ruling is applicable in the case under
ownership filed by Degayo) consideration."
- The disputed properties are abandoned ITCAB: Degayo’s objection to the action of CA on this
riverbeds. Being abandoned riverbeds, the matter is merely technical because Degayo herself
property in question rightfully belongs to the repeatedly referred to the Civil Case No. 16047 in her
respondents as the owners of the land now pleadings in Civil Case No. 18328 and even in her
occupied by the Jalaud River. appellee’s brief before the CA and her petition for review
- The previous RTC Branch decision in Civil Case before this Court. The existence of that case was likewise
No. 16047 is conclusive to the title of the thing, jointly stipulated by that parties in Civil Case No. 1832840
being an aspect of the rule on conclusiveness of and mentioned by the court a quo in its decision. In her
judgment. appellee’s brief as well, Degayo expressly referred to Civil
Case No. 16047. In particular, she stated:
II. ISSUE
THEREFORE, there was thus no denial of the existence
W/N the CA erred in taking judicial notice of the RTC and the decision in Civil Case No. 16047. In fact, Degayo
decision in Civil Case No. 16047 (civil case filed by the stated on record her full knowledge of Civil Case No.
respondents) when it was not even presented during the 16047 and clearly and frequently referred to it in her
hearing of the present case: NO pleadings, and sufficiently designated it by name, parties,
cause of action and docket number from the court a quo,
to the CA and even before this Court.
III. RATIONALE
Republic v. CA: "A court will take judicial notice of its own
The taking of judicial notice is a matter of expediency and
acts and records in the same case, of facts established in
convenience for it fulfills the purpose that the evidence is
prior proceedings in the same case, of the authenticity of
intended to achieve, and in this sense, it is equivalent to
its own records of another case between the same
proof.
parties, of the files of related cases in the same court, and
GENERAL RULE: courts are not authorized to "take of public records on file in the same court. In addition
judicial notice of the contents of the records of other cases judicial notice will be taken of the record, pleadings or
even when said cases have been tried or are pending in judgment of a case in another court between the same
the same court or before the same judge parties or involving one of the same parties, as well as of
the record of another case between different parties in the
EXCEPTIONS: cited in Tiburcio v PHHC same court. " Lastly, there is another equally compelling
1. courts have taken judicial notice of proceedings consideration. Degayo undoubtedly had recourse to a
in other causes, because of their close remedy which under the law then in force could be availed
connection with the matter in the controversy. of, which is to file a petition for certiorari with the CA. It
a. Thus, in a separate civil action against would have served the cause of justice better, not to
the administrator of an estate arising mention the avoidance of needless expense on her part
from an appeal against the report of the and the vexation to which the respondents were subjected
committee on claims appointed in the if she did reflect a little more on the matter.
administration proceedings of the said
estate, to determine whether or not the IV. DISPOSITIVE
appeal was taken on time, the court
took judicial notice of the record of the WHEREFORE, premises considered, we DENY the
administration proceedings. petition for lack of merit. Costs against the petitioner.
2. Courts have also taken judicial notice of previous
cases to determine whether or not the case
pending is a moot one or whether or not a