Beltran vs. Escudero

Facts:

Petra Beltran, et als. v. Arsenio Escudero, et als., G.R. No. L-7983, July 31, 1956, Supreme Court En Banc, Montemayor, J., writing for the Court.

The plaintiffs-appellants are the five children of Eulalio Beltran; the defendants-appellees are Arsenio Escudero and his wife Rosario Adap. The dispute concerns a parcel of land in San Pablo City that their mother Simeona de Mesa purchased on July 13, 1912, during her marriage to Regino Beltran, who had abandoned the conjugal home in 1902 and died in 1925.

In 1939 Simeona and sometimes her son Mariano managed the lot and on October 11, 1939, it was sold to Escudero and Adap. One of Simeona’s children, Romualda, had earlier married Ponciano Flores and bore nine children; Romualda died in 1941 and Simeona died two years later. On May 9, 1949 Romualda’s children filed Civil Case No. 9269 against Escudero and Adap to recover 1/6 of the parcel, alleging it formed part of the conjugal property of Simeona and Regino and that Romualda inherited a share. The trial court in that case, on the basis of stipulations and admissions, ordered the reconveyance of one-sixth and recovery of rentals; on appeal this Court affirmed with modification in G.R. No. L-5302 (decision promulgated March 11, 1953).

On August 1, 1949 the present plaintiffs (the children of Eulalio) filed Civil Case No. 9298 against the same defendants claiming an equal 1/6 share as heirs of Regino. They relied on the prior proceedings in Civil Case No. 9269 and offered the first case’s decision, pleadings, stipulation and record to show that the question of ownership had been decided. The trial court, however, received additional evidence from defendants showing different facts: Simeona had in 1904–08 given advances of inheritance to her children; on July 11, 1928 she donated the San Pablo lot to Mariano (Eulalio signed as witness), Mariano mortgaged the lot to Eulalio in 1936 for P700 (indicating Mariano’s ownership), and in 1939–41 Eulalio joined an amicable settlement expressly consenting to the sale to Escudero and Adap.

Judge Arguelles of the Court of First Instance of Laguna rendered judgment on December 27, 1951 dismissing the complaint for lack of evidence and merit and held plaintiffs had prosecuted the action with malice, awarding defendants P500 attorney’s fees on counterclaim plus costs. Plaintiffs moved for new trial on February 8, 1952 and, after filing additional grounds on March 18, 1953 (including the prior Supreme Court decision in G.R. No. L-5302), the presiding judge changed to Judge Jose M. Mendoza, who on June 22, 1953 granted reconsideration and ordered a new trial. After the new trial Judge Mendoza reaffirmed Judge Arguelles’s factual findings, held that Eulalio’s express consent and acts amounted to a renunciation/waiver of any interest, and again dismissed the complaint. Plaintiffs appealed to this Court, assigning as errors that the lower court erred in failing to hold that defendants were estopped by the prior judgment and in permitting evid...(Pro-only)

Issues:

• Are the defendants estopped by the prior judgment in Civil Case No. 9269 (and the stipulation made in that case) from denying the plaintiffs’ claimed one-sixth interest (i.e., does estoppel by record or res judicata bar relitigation here)?
• Did the trial court err in admitting and considering evidence beyond the record in Civil Case No. 9269 and in disregarding the prior Supreme Court decision when those facts were relev...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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