Facts:

The case of Avisado v. Rumbaua revolves around a dispute concerning property ownership and occupancy. The respondents, Amor Rumbaua and Victoria Consengco-Rumbaua, who are a married couple residing in Jacksonville, Florida, became the registered owners of a parcel of land measuring 235.60 square meters in Quezon City on July 1, 1971, under Transfer Certificate of Title No. 166065. Their title was adjacent to another lot owned by Rafael and Aurora Consengco, who were registered owners of a lot of similar size adjacent to Rumbaua's property. In February 1973, the Rumbaus discovered that Abelardo Avisado and his wife, Virginia Avisado, had occupied both parcels and built a bungalow without their consent. The Rumbaus demanded evacuation, which was not complied with by the Avisados.

In December 1977, Victoria executed a "special power of attorney" allowing Rafael to manage legal actions regarding their property. On November 17, 1978, the Rumbaus, represented by Rafael,

Facts:

The dispute arose from the occupation of two parcels of land in Quezon City by the Avisados. In 1971, Victoria became the registered owner of one lot (TCT No. 166065) and, shortly after, Rafael and Aurora became registered owners of the adjacent lot (TCT No. 166066). In early 1973, Amor and Victoria, together with Rafael and Aurora, discovered that the Avisados were occupying both lots and had constructed a bungalow thereon. Despite repeated demands to vacate, the Avisados remained in possession. In December 1977, Victoria executed a special power of attorney authorizing Rafael to represent her in recovering her property. Subsequently, on November 17, 1978, the vendors (Amor, Victoria, Rafael, and Aurora) filed a complaint for recovery of possession with damages. On April 15, 1980, a compromise agreement was reached whereby the Avisados agreed to purchase the lot from the vendors for P70,000.00 with payment in installments; among other stipulations, the Avisados were required to remove their house from the lot and pay further amounts otherwise triggering forfeiture of a sum and cancellation of the agreement. The trial court approved the compromise agreement, and later, further proceedings—including motions for execution—ensued. However, on October 29, 1993, Amor and Victoria filed a separate complaint for recovery of possession and damages, contending that the special power of attorney did not authorize Rafael to sell the lot and alleging that the compromise agreement was invalid. Eventually, after various pleadings and a previous appellate decision approving the compromise agreement, the trial court dismissed the later complaint for being barred by prior judgment. Appeals and motions for reconsideration followed, with the case finally reaching the Supreme Court for review on the issue of whether the earlier decision (Civil Case No. Q-26392) should bar the present suit (Civil Case No. Q-93-18138) on the doctrine of res judicata and whether the allegations were time-barred by laches.

Issue:

The central issue is whether the Court of Appeals erred in not considering the decision in Civil Case No. Q-26392 as a bar to the subsequent Civil Case No. Q-93-18138, given that the parties are attempting to relitigate matters previously decided—specifically, the validity and performance of the compromise agreement. Additionally, the Court had to determine whether the earlier judgment, now final and executory, and the long delay (laches) in pursuing the alternative claim, precluded the present action.

Ruling:

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Ratio:

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Doctrine:

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