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...

Facts:

Procedural Background

• The case involves an appeal from the Court of First Instance of Manila, which dismissed the complaint in Civil Case No. Q-5046 filed by Tomas Alarcon.
• The dismissal was based on the doctrine of lis pendens, meaning that another legal action on the same subject matter is pending.
• The appeal was initially brought to the Court of Appeals but was certified to the Supreme Court on the ground that only questions of law were involved.

Allegations and Causes of Action Raised by the Plaintiff-Appellant

• First Cause of Action
• On March 18, 1949, Agustin de Torres, predecessor in interest of defendant Rufina Guerrero (widow de Torres), executed a deed of sale conveying a 1,000 square meter parcel of land to Tomas Alarcon for P3,000.
• The sale stipulated that P300 was paid at the time of contract signing, with the balance of P2,700 to be paid within ten years.
• Plaintiff’s repeated tenders to pay the balance were refused by Rufina Guerrero.
• Second Cause of Action
• On September 9, 1958, a separate complaint was filed by defendant J. M. Tuason & Co., Inc. in Civil Case No. Q-3277, wherein it asserted its ownership over a parcel of land covered by T.C.T. No. 1267.
• A portion of this parcel, identified as Lot No. 20, is the same lot that the plaintiff alleged was contracted to be sold by Agustin de Torres.
• The defendant claims that as a result of this other complaint, the plaintiff faces the risk of eviction and the obligation to pay a monthly rental for the use and occupation of the lot.
• Third Cause of Action
• On March 16, 1953, defendant Rufina Guerrero (as successor-in-interest of Agustin de Torres) and other persons (collectively referred to as the “DEUDORS”) entered into a Compromise Agreement with defendant J. M. Tuason & Co., Inc.
• Under the agreement, the DEUDORS purportedly sold the possessory rights over several parcels of land, including the lot allegedly contracted to the plaintiff.
• The complaint further requests that, in conforming to the Compromise Agreement, defendant J. M. Tuason & Co., Inc. be ordered to:
• Enter into a new contract of purchase with the plaintiff regarding Lot No. 20; and
• Deduct any excess arising from a higher current price per square meter compared to the agreed price, from a sum amounting to P189,511.77 due under Condition No. SIXTH of the agreement.
• The plaintiff further prays for the execution and delivery of the final deed of conveyance and title to the lot and for recognition of his quiet and peaceful possession pending the transfer.

Lis Pendens Argument

• The defendant J. M. Tuason & Co., Inc. filed a motion to dismiss the amended complaint, arguing that another action is already pending between the same parties for the same cause.
• The requisites of lis pendens cited include:
• Identity of the parties, or parties presenting the same interests in both actions;
• Identity of the rights asserted and the relief prayed for, based on the same set of facts; and
• The pending judgment in one case would result in res judicata in the other, regardless of which party is successful.
• It is established that Civil Case No. Q-3277, involving the same lot and conflicting claims over title, is pending, thereby raising the possibility that a decision therein could preclude subsequent litigation in the present case.

Central Point of Contention

• The plaintiff-appellant argues that despite the existence of the parallel case, there is no valid lis pendens and hence his complaint should proceed.
• The Supreme Court had to examine whether the causes of action in the two cases are identical such that a decision in the pending Civil Case No. Q-3277 would operate as res judicata in Civil Case No. Q-5046.

Issue:

• Whether the existence of another pending case (Civil Case No. Q-3277) involving the same parties and the identical parcel of land constitutes a valid ground for the dismissal of the complaint in Civil Case No. Q-5046 based on lis pendens.
• Whether the claims and causes of action in both cases are sufficiently identical in terms of the rights asserted and the relief sought, so that the judgment in the pending case would have a preclusive effect (res judicata) on the present complaint.
• Whether the preliminary finding of ownership of the land, which is central to both actions, necessitates that the issues be consolidated in one case to avoid inconsistent judicial determinations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)