Case Digest (G.R. No. L-52092)
Facts:
The case involves plaintiffs-appellants Leonardo Avedana and Purificacion Timbang against defendant-appellee Manolito Bautista and the Court of First Instance of Pasay City, Branch XXIX. The events leading to this case began with a lease agreement allegedly executed between Manuel Bautista, the father of Manolito Bautista, and Fausta Timbang, the mother of the plaintiffs, concerning a parcel of land. On November 11, 1977, the plaintiffs filed a complaint in the Court of First Instance of Rizal seeking to annul a judgment rendered in Civil Case No. 3782-P, which had been initiated by Manolito Bautista for the recovery of possession of the same parcel of land. The original decision in Civil Case No. 3782-P was rendered on May 26, 1973, and was subsequently affirmed by the Court of Appeals on February 11, 1977. In their complaint for annulment, the plaintiffs alleged that the court acted in bad faith and fraudulently rendered a decision favoring the private respondent, disregard...
Case Digest (G.R. No. L-52092)
Facts:
Background of the Case:
- Plaintiffs-appellants Leonardo Avedana and Purificacion Timbang filed a complaint to annul the judgment rendered by the Court of First Instance of Rizal in Civil Case No. 3782-P.
- The original case (Civil Case No. 3782-P) was filed by defendant-appellee Manolito Bautista for the recovery of possession of a parcel of land. Plaintiffs-appellants claimed to be lessees of the land under a lease contract allegedly executed between Manuel Bautista (father of Manolito Bautista) and Fausta Timbang (mother of the plaintiffs-appellants).
Decision in Civil Case No. 3782-P:
- The Court of First Instance of Rizal ruled in favor of Manolito Bautista on May 26, 1973.
- Plaintiffs-appellants appealed to the Court of Appeals, which affirmed the decision with modifications on February 11, 1977.
Allegations in the Annulment Case:
- Plaintiffs-appellants alleged that the Court of First Instance acted in "evident bad faith" and rendered a fraudulent decision, knowing it lacked jurisdiction over the case.
- They claimed that the court disregarded the testimony of Manuel Bautista, a hostile witness, to their detriment.
- Plaintiffs-appellants argued that Manolito Bautista, as the heir of Manuel Bautista, was bound by the lease agreement executed between Manuel Bautista and Fausta Timbang.
Motion to Dismiss:
- Defendant Manolito Bautista filed a motion to dismiss, arguing that the plaintiffs' cause of action was barred by prior judgment and that the complaint was a tactic to delay the execution of the final decision in Civil Case No. 3782-P.
- The Court of First Instance granted the motion to dismiss on March 29, 1978, and denied plaintiffs' motion for reconsideration.
Appeal to the Supreme Court:
- Plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court as involving purely questions of law.
Issue:
- Whether the complaint for annulment of judgment filed by plaintiffs-appellants is barred by prior judgment.
- Whether the allegations of fraud in the complaint constitute sufficient grounds for annulment of the judgment in Civil Case No. 3782-P.
- Whether the trial court properly dismissed the complaint for lack of cause of action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court dismissed the appeal, affirming the lower court's order dismissing the complaint. The Court emphasized that litigations must come to an end, and parties cannot use allegations of intrinsic fraud to relitigate issues already decided by a final judgment.