Title
Adiarte vs. Domingo
Case
G.R. No. 47301
Decision Date
Apr 8, 1941
Plaintiff seeks delivery of goods previously litigated; court dismisses case, citing res adjudicata and judicial notice of prior judgment.
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Case Digest (G.R. No. 47301)

Facts:

Background of the Case:
On March 22, 1928, Godofredo Domingo, acting as the authorized representative of Pastor Domingo (defendant), filed a case in the Court of First Instance of Ilocos Norte (Civil Case No. 3011) to recover the sum of P1,150. This amount represented the price of lumber, alcohol, and shellac that Pastor Domingo had obligated himself to deliver to Pedro Adiarte (plaintiff).

Defense and Initial Judgment:
Pedro Adiarte defended himself by claiming that the goods were not delivered. The court ruled against him, and this judgment was affirmed by the Supreme Court. As a result, Adiarte's real property was sold at a public auction to satisfy the judgment.

Subsequent Action:
One year later, on October 17, 1936, Pedro Adiarte filed the present action against Pastor Domingo, seeking to compel the delivery of the same lumber, alcohol, and shellac that were the subject of his defense in the prior case.

Demurrer and Amendments:
The defendant filed a demurrer, arguing that the case was barred by res adjudicata (a matter already judged). The trial court sustained the demurrer, and the Supreme Court affirmed the decision but allowed the plaintiff to amend his complaint. However, the amended complaint introduced no new facts to establish a proper cause of action. A second demurrer was filed, which the trial court also sustained, leading to the dismissal of the amended complaint.

Judicial Notice of Prior Case:
The plaintiff argued that the trial court erred in taking judicial notice of the records in Civil Case No. 3011. However, the Supreme Court clarified that the trial court was justified in considering the prior case, as the plaintiff himself had referenced it in his complaint.

Issue:

  1. Whether the present action is barred by res adjudicata due to the prior judgment in Civil Case No. 3011.
  2. Whether the trial court erred in taking judicial notice of the records in the prior case.

Ruling:

The Supreme Court affirmed the trial court's order sustaining the demurrer and dismissing the amended complaint. The Court held that the doctrine of res adjudicata applied, as the present action involved the same subject matter and parties as the prior case. Additionally, the Court ruled that the trial court did not err in taking judicial notice of the records in Civil Case No. 3011, as the plaintiff had referenced the case in his complaint.

Ratio:

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