Facts:

The case at bar, Basilio Aquino vs. Jose G. Sanvictores and Pastor Pangilinan, involves an appeal by Basilio Aquino from a resolution of the Court of First Instance of Bulacan that dismissed his complaint against Jose G. Sanvictores and Pastor Pangilinan on the ground of res judicata. The background of the dispute rests primarily on the ownership and possession of Lot No. 19, Block 83 of the Hacienda de Buenavista. In a previous case (Civil No. 61), decided by the Court of Appeals on November 29, 1948, Basilio Aquino was the plaintiff, and Pastor Pangilinan was the defendant. The appellate court awarded possession of the contested lot to Pangilinan, establishing that Aquino had occupied the lot under a lease agreement but had failed to pay the required rent. The court found that the lease was lawfully canceled by the Hacienda’s administrator after Aquino refused to comply with his obligations. Consequently, Pangilinan was confirmed as the rightful owner after the Commonwealth of

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Facts:

Parties Involved

• Basilio Aquino – Plaintiff and Appellant.
• Jose G. Sanvictores – Defendant and Appellee, manager or administrator of the Hacienda de Buenavista.
• Pastor Pangilinan – Defendant and Appellee, later declared owner of the disputed lot.

Procedural History and Chronology

• Initial Action (Civil Case No. 61)
• Basilio Aquino filed a complaint regarding possession of lot No. 19 Block 83 of the Hacienda de Buenavista.
• The case was eventually decided by the Court of Appeals on November 29, 1948.
• The appellate court held that the lot had been lawfully taken over by Pastor Pangilinan after a series of events, including:
• Aquino’s original occupation as a tenant or lessee before 1939.

ii. The leasing of the Hacienda to the Commonwealth of the Philippines on March 4, 1939, which included an option to purchase for P3,000. iii. The confirmation or renewal of Aquino’s lease by the Commonwealth through the Rural Progress Administration, with the contract of sublease executed on December 18, 1939. iv. The cancellation of the sublease on April 17, 1940 due to Aquino’s refusal to pay the agreed rent. ii. In April 1940, Sanvictores, in connivance with Pangilinan, arbitrarily cancelled the lease contract and forcibly ejected him. iii. The ejection resulted in damage and prejudice amounting to P26,380.

Underlying Facts Pertinent to the Res Judicata Issue

• Identity of the Subject Matter
• Both actions involved the same disputed lot within the Buenavista Estate.
• Issues of possession, cancellation of the lease contract, and alleged forceful ejection were identical in both cases.
• Previous Judicial Determination
• The prior case (Civil Case No. 61) resolved the matter on the basis of Aquino’s non-compliance with rent and his voluntary relinquishment of the lot.
• The ruling established the chain of events leading to the recognized ownership and possession of the property in favor of Pastor Pangilinan.
• Joinder of Parties
• Although Sanvictores was not a formal party in the initial litigation, his participation as a figure closely involved in the lease contract and subsequent events made him, in effect, a necessary party.
• Aquino’s attempt to include Sanvictores in the subsequent suit aimed to re-litigate the same matters already decided in the earlier case.

Issue:

• Whether the instant litigation, based on the same lease contract and allegations of illegal cancellation and forcible ejection, is barred by the doctrine of res judicata due to the prior adjudication in Civil Case No. 61.
• Whether the judicial determination in the previous case, which validated the cancellation of the lease contract and the subsequent relinquishment of possession by Aquino, conclusively precludes his present claim for restitution of possession and damages.
• Whether the inclusion of additional parties (specifically, Sanvictores) in the subsequent suit, who were not joinder parties in the original litigation, affects the applicability of the res judicata doctrine.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)