Facts:

The case of Pablo Arceo vs. Jose Oliveros and Rufina Cabangon arose from a dispute over a parcel of land inherited from their deceased father, Roberto Arceo. On June 27, 1963, Pablo Arceo (plaintiff-appellant), filed a complaint against spouses Jose Oliveros and Rufina Cabangon (defendants-appellees) before the then Court of First Instance of Quezon, claiming a right of redemption under Section 119 of the Public Land Act (Commonwealth Act No. 141). Pablo alleged that his sister and co-heir, Sixta Arceo, sold her undivided interest in the land to the defendants on July 10, 1958, without his consent for P2,500.00. He contended that the defendants had not made any improvements on the property since the sale and sought to redeem the land, which was covered by a free patent title.

The defendants filed a motion to dismiss the complaint, raising several grounds, including that Pablo lacked legal capacity to sue and that there was another pending action involving the same parties and ca

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Facts:

Background of the Case

• Plaintiff-appellant Pablo Arceo filed a complaint seeking to exercise his right of redemption under Section 119 of the Public Land Act (Commonwealth Act No. 141).
• The dispute arises from the sale of a parcel of land, which was inherited by Pablo Arceo and his sister Sixta Arceo, to defendants-appellees, the spouses Jose Oliveros and Rufina Cabangon.
• Pablo claimed that the sale executed by his sister on July 10, 1958, occurred without his consent and that the defendants have continuously enjoyed the property without making improvements despite his co-ownership.

Procedural History and Pleadings

• On June 27, 1963, Pablo Arceo initiated the action in the then Court of First Instance of Quezon.
• Defendants moved to dismiss the complaint on several grounds:
• Plaintiff’s lack of legal capacity to sue.
• Existence of another pending action between the same parties for the same cause.
• Bar of the cause of action by the statute of limitations.
• The complaint’s failure to state a cause of action.
• The prosecution of the action not being in the name of the real party in interest.
• The court a quo denied the motion to dismiss and directed the defendants to file their Answer.
• In their Answer, defendants asserted that:
• Sixta Arceo sold her definite share in the disputed 1½-hectare parcel for P2,500.00.
• A definite partition of the subject property between Pablo and his sister had already been made prior to the sale.
• The conveyance occurred only after Pablo’s stated unwillingness and inability to buy the portion offered to him.
• The defendants had made several improvements on the property.
• Subsequently, on June 23, 1965, the parties agreed to resolve the case based on their pleadings and documentary evidence.
• The Court of First Instance rendered a decision on September 7, 1965, dismissing the plaintiff’s complaint, a ruling which was later affirmed by denying his motion for reconsideration.
• The case reached the Supreme Court on appeal, with the pivotal issue revolving around the application of the doctrine of lis pendens due to the existence of another pending suit (Civil Case No. 435-G) between the same parties and involving similar issues.

Contentions and Submissions

• Plaintiff-appellant contended that:
• The two cases involve distinct rights and reliefs – the earlier suit sought to enforce the sale, whereas the present suit sought to redeem the property.
• Acceptance of lis pendens should not bar the later action since the reasons and consequences differ depending on the outcome of the earlier suit.
• The “analogous case” of Hongkong & Shanghai Bank vs. Aldecoa & Co. was cited in support, arguing that differing claims (annulment versus foreclosure) permit simultaneous actions.
• Defendants-appellees argued that:
• The compulsory redemption issue, already asserted by Pablo Arceo as a counterclaim in Civil Case No. 435-G, was identical to the cause of action in the present suit.
• There was no substantive difference between the claims as the issues and parties involved remained the same, notwithstanding a mere change in the party’s position (from plaintiff to defendant and vice versa).
• Splitting a single cause of action by asserting it both as a counterclaim and as a separate complaint violates the procedural rule against multiple litigation over the same subject matter.

Issue:

• Whether the pending Civil Case No. 435-G, involving the same parties, identical subject matter, and the identical issue of compulsory redemption, gives rise to the doctrine of lis pendens thereby necessitating the dismissal of the present suit.
• Whether Pablo Arceo possessed the legal capacity to sue, given his previous participation in the pending suit as a defendant asserting a compulsory counterclaim.
• Whether the legal redemption provided under Articles 1612 and 1614 of the Civil Code can supplement the right of redemption under Section 119 of the Public Land Act.
• The effect of asserting a cause of action (compulsory redemption) in both a counterclaim and a separate complaint on the validity of the petition.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)