Case Digest (G.R. No. 160994)
Facts:
Wilfredo and Swarnie Aromin v. Paulo Floresca, Victor Floresca, Juanito Floresca and Lilia Floresca-Roxas, G.R. No. 160994, July 27, 2006, Supreme Court First Division, Callejo, Sr., J., writing for the Court.The dispute arose from three consolidated civil actions before the Regional Trial Court (RTC), Bauang, La Union, Branch 67: (1) Civil Case No. 921-BG (specific performance) filed by the spouses Wilfredo and Swarnie Aromin against Paulo Floresca to compel execution of deeds of sale over portions of Cad. Lot No. 4894; (2) Civil Case No. 938-BG (quieting of title) by the Aromins against Victor, Juanito and Lilia Floresca and Paulo; and (3) Civil Case No. 965-BG (annulment of sale) filed by the Floresca siblings against Paulo and the Aromins. The Aromins alleged Paulo sold them several unregistered parcels between 1990 and 1992 (totaling 98,257 sq. m.), supported by a receipt and multiple deeds of sale; the siblings contended the lot was co-owned by Paulo and the Floresca siblings and pointed to an earlier partition suit, Civil Case No. 832-BG, which resulted in a judgment based on compromise dated February 10, 1993, partitioning Cad. Lot No. 4894 between Paulo and the siblings.
During pre-trial the parties stipulated to key facts: the existence of the judgment based on compromise in Civil Case No. 832-BG; that the Aromins were not parties to that case; that a notice of lis pendens had been recorded on August 16, 1991; that several deeds of sale and acknowledgments were unregistered and some were executed after the filing of Civil Case No. 832-BG; and that the Deed of Sale of February 10, 1994 and related documents came after the partition suit. Paulo later died and his heirs were substituted in the consolidated suits.
After trial, the RTC (Branch 67) rendered judgment on September 15, 2000 in favor of the Aromins, finding Paulo to be the sole owner, declaring the Aromins buyers in good faith, and holding that the judgment in Civil Case No. 832-BG did not bind the Aromins. The RTC credited Paulo’s testimony about ownership and the Aromins’ lack of notice and rejected the siblings’ claim of co-ownership and bad faith on the part of the Aromins. On appeal, the Court of Appeals (CA) in a Decision dated June 6, 2003 (CA‑G.R. CV No. 69651) reversed: it held the 1993 judgment based on compromise in Civil Case No. 832-BG binding on the Aromins (as privies/successors-in-interest of Paulo), ruled the Aromins were not buyers in good faith and that any sale by Paulo conveyed only his one-half share, and awarded moral damages (P250,000) and attorney’s fees (P50,000) against...(Subscriber-Only)
Issues:
- Are the petitioners (the Aromins), although not parties to Civil Case No. 832-BG, bound by the judgment based on compromise in that case (i.e., does res judicata/privy doctrine apply)?
- Were the petitioners buyers in good faith such that their purchase from Paulo conveyed ownership of the whole property, or is any conveyance limited to Paulo’s one-half share?
- If the petitioners must relinquish one-half of the property, are Paulo’s heirs obliged to reimburse the peti...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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