Case Digest (G.R. No. L-21656)
Facts:
The case involves Tomas Alarcon as the plaintiff-appellant and Rufina Guerrero Vda. de Torres along with J. M. Tuason & Co., Inc. as the defendants-appellees. The events leading to this case began on March 18, 1949, when Agustin de Torres, the predecessor in interest of Rufina Guerrero, executed a deed of sale to Alarcon for a parcel of land measuring 1,000 square meters for the price of P3,000. Alarcon paid P300 upon signing the contract, with the remaining P2,700 to be paid within ten years. However, Rufina Guerrero refused to accept the balance despite Alarcon's repeated offers.
On September 9, 1958, J. M. Tuason & Co., Inc. filed a complaint against Alarcon, which was docketed as Civil Case No. Q-3277, claiming ownership of a parcel of land covered by T.C.T. No. 1267, which included Lot No. 20, the same lot contracted to be sold to Alarcon. This situation placed Alarcon at risk of eviction and potential liability for the use of the land, which Tuason claime...
Case Digest (G.R. No. L-21656)
Facts:
Background of the Case
- Tomas Alarcon (plaintiff-appellant) filed a complaint for "Specific Performance, Damages, etc." against Rufina Guerrero Vda. de Torres and J. M. Tuason & Co., Inc. (defendants-appellees).
- The Court of First Instance of Manila dismissed the complaint on the ground of lis pendens, as there was already a pending case involving the same parties and subject matter.
First Cause of Action
- On March 18, 1949, Agustin de Torres (predecessor-in-interest of Rufina Guerrero) executed a deed of sale in favor of Tomas Alarcon for a parcel of land (Lot No. 20) measuring 1,000 square meters for P3,000.
- P300 was paid upon signing, and the remaining P2,700 was to be paid within ten years.
- Rufina Guerrero refused to accept the balance despite repeated tenders by Alarcon.
Second Cause of Action
- On September 9, 1958, J. M. Tuason & Co., Inc. filed a complaint (Civil Case No. Q-3277) against Tomas Alarcon, claiming ownership of the same parcel of land (Lot No. 20) under Transfer Certificate of Title (TCT) No. 1267.
- J. M. Tuason & Co., Inc. sought to evict Alarcon and recover the reasonable value for the use and occupation of the land.
Third Cause of Action
- On March 16, 1953, Rufina Guerrero (as successor-in-interest of Agustin de Torres) and other "DEUDORS" entered into a Compromise Agreement with J. M. Tuason & Co., Inc.
- The agreement included the sale of possessory rights over the land, including Lot No. 20, which Agustin de Torres had previously sold to Alarcon.
- Alarcon argued that J. M. Tuason & Co., Inc. should recognize his rights under the Compromise Agreement and enter into a new contract of purchase with him.
Prayer in the Complaint
- Alarcon sought specific performance, asking the court to order J. M. Tuason & Co., Inc. to:
- Enter into a new contract of purchase with him for Lot No. 20.
- Deduct any price difference from the P89,511.77 owed to Rufina Guerrero under the Compromise Agreement.
- Execute and deliver the final deed of conveyance and title to Lot No. 20.
- Alarcon sought specific performance, asking the court to order J. M. Tuason & Co., Inc. to:
Motion to Dismiss
- J. M. Tuason & Co., Inc. filed a motion to dismiss the complaint on the ground of lis pendens, arguing that Civil Case No. Q-3277 was already pending and involved the same parties and subject matter.
- The trial court granted the motion to dismiss, prompting Alarcon to appeal.
Issue:
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Ruling:
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Ratio:
Lis Pendens Requirements: For lis pendens to apply, there must be:
- Identity of parties or interests.
- Identity of rights asserted and relief prayed for, based on the same facts.
- A judgment in the pending case that would constitute res judicata in the later case.
Identity of Causes of Action:
- In Civil Case No. Q-3277, J. M. Tuason & Co., Inc. sought to recover possession of Lot No. 20 based on its claim of ownership under TCT No. 1267.
- In Civil Case No. Q-5046, Alarcon sought to enforce his rights under the Compromise Agreement, which also required a determination of ownership.
- Both cases hinged on the issue of ownership, making the judgment in the pending case (Q-3277) res judicata in the later case (Q-5046).
Precedents: The Court cited previous cases involving the same Compromise Agreement, where actions were dismissed on the grounds of lis pendens or res judicata due to the identity of parties and subject matter.
Conclusion:
The Supreme Court upheld the dismissal of Civil Case No. Q-5046, ruling that the requisites for lis pendens were met. The judgment in Civil Case No. Q-3277 would resolve the issue of ownership, which is central to both cases, making further litigation in Civil Case No. Q-5046 unnecessary.