Facts:

The case of Atanacio Robis vs. Susana Caspe and Ireneo Araw, G.R. No. L-6166, was decided on September 28, 1954. The plaintiff-appellant, Atanacio Robis, initiated legal proceedings against the defendants-appellees, Susana Caspe and Ireneo Araw, seeking recovery of a parcel of land. The case arose from a series of events that began in 1932, when Ceferino Oligario first occupied and cleared what was originally a public forest. In 1947, Oligario declared the land for taxation purposes in his name (Exhibit B). The following year, 1948, Robis declared the same land for tax purposes under his name (Exhibit C) and paid taxes for the years 1947 and 1949 (Exhibits D and D-1).

On April 15, 1940, Robis purchased the land from Oligario through a private document of sale (Exhibit E). Subsequently, on May 27, 1941, Oligario executed another deed of sale before Notary Public Marcelino Libanan, again in favor of Robis (Exhibit F). However, a conflict over possession of the land led to Civil Ca

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Facts:

Background of the Land and Its Transactions

• The parcel in dispute was originally a public forest.
• In 1932, Ceferino Oligario occupied and cleared the area.
• In 1947, Ceferino Oligario declared the land in his name for taxation purposes (Exhibit B).
• In 1948, plaintiff-appellant Atanacio Robis declared the same land in his name for taxation purposes (Exhibit C).
• Robis subsequently paid the corresponding land taxes for the years 1947 and 1949 (Exhibits D and D-1).

Deeds of Sale and Possession

• On April 15, 1940, Robis purchased the land from Ceferino Oligario by virtue of a private document of sale (Exhibit E).
• A second deed of sale was executed on May 27, 1941, by Oligario in favor of Robis before Notary Public Marcelino Libanan (Exhibit F).
• Despite these transactions, the title or ownership of the land was not conclusively established, as the acts of merely clearing a public forest and paying taxes did not suffice to constitute valid title.

Prior Litigation Over Possession

• The land’s possession had been the subject of litigation in Civil Case No. 222 for forcible entry, styled Atanacio Robis vs. Ireneo Araw and Susan Caspe, before the Justice of the Peace of Dolores, Samar.
• A decision was rendered in the plaintiff’s favor on June 23, 1946 (Exhibit G).
• The defendants appealed the decision, and the case was docketed in Civil Case No. 37 in the Court of First Instance, where on May 22, 1951, the court condemned Robis to restore and deliver the land to the defendants.
• On February 20 or 26, 1952, the Deputy Provincial Sheriff, Mr. Jose R. Amores, executed the order of delivery of the land to the defendants (Exhibit H).

The Trial Court's Conclusion

• Based on the facts and prior decision, the trial judge concluded that the defendants' possession of the land was already “res adjudicata.”
• Consequently, Robis was estopped from asserting his claim based on the events of December 1945, when he alleged that the defendants ejected him by force.

Issue:

Whether the doctrine of res judicata (or res adjudicata) applied to bar the plaintiff-appellant’s claim for recovery of the land.

• The plaintiff contended that although the parties and the subject matter were identical in both the present suit and the earlier Civil Case No. 37, there was no identity of the cause of action, given that the present action aimed at recovery of dominion while the earlier case involved mere possession.
• Whether the previous judgment, resulting from the forcible-entry litigation, concluded the rights of possession and thereby precluded any fresh litigation over the same issue.

The Effect of Dismissal by Default

• Whether dismissal by default, under section 3, rule 30 of the Rules of Court (which states that a dismissal shall have the effect of an adjudication on the merits), barred the plaintiff from raising a different cause of action in the current suit.
• Whether a judgment based on issues previously litigated should preclude a claim based on a different facet (i.e., dominion instead of mere possession), when the underlying facts were substantially the same.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)