Case Digest (G.R. No. L-6337)
Facts:
The case involves Ruperta Camara, Natalia Camara, Zosima Gamara, Abignigo Camara, Sadrac Camara, and Rebeca Camara as plaintiffs and appellants against Celestino Aguilar, Roberta Aguilar, Alicia Aguilar, and Rodelo Aguilar, represented by their guardian ad litem Purificacion Villamiel, as defendants and appellees. The events leading to this case began with the plaintiffs claiming ownership of a 5-hectare parcel of land located in Balubad, Atimonan, Quezon, which they inherited from their father, Severino Camara. Severino had been in continuous possession of the land since 1915, having cultivated it and planted 1,500 coconut and other fruit-bearing trees. After Severino's death, the plaintiffs asserted their ownership of the land and sought to recover P300 for clearing the land, P750 for its cultivation, and P10,100 for the value of the trees planted.
The legal background includes a prior ejectment case (Civil Case No. 4835) filed by Fausto Aguilar against Vicenta Nera,...
Case Digest (G.R. No. L-6337)
Facts:
Parties Involved:
- Plaintiffs-Appellants: Ruperta Camara, Natalia Camara, Zosima Gamara, Abignigo Camara, Sadrac Camara, and Rebeca Camara (represented by her guardian ad litem, Ruperta Camara).
- Defendants-Appellees: Celestino Aguilar, Roberta Aguilar, Alicia Aguilar, and Rodelo Aguilar (the last three represented by their guardian ad litem, Purification Villamiel).
Subject Matter:
- The case involves a parcel of land located in Balubad, Atimonan, Quezon, with an area of approximately 5 hectares.
- The land was inherited by Severino Camara (plaintiffs' father) from his parents, Paulino Camara and Modesta Villamorel.
Claims of the Plaintiffs:
- The plaintiffs claimed that they and their deceased father, Severino Camara, had been in continuous and uninterrupted possession of the land since 1915.
- They alleged that they spent P300 for clearing the land and P750 for cultivating it, planting 1,500 coconut and other fruit-bearing trees.
- They sought to recover P10,100, representing the value of the trees, or alternatively, to be declared entitled to pay the reasonable value of the land.
Prior Litigation (Civil Case No. 4835):
- Fausto Aguilar (father of the defendants) filed an ejectment case (reivindicacion) against Vicenta Nera (plaintiffs' mother) over the same land.
- The Court of First Instance ruled in favor of Fausto Aguilar, declaring him the absolute owner and ordering the defendants and intervenors (plaintiffs in this case) to restore possession and pay P1,200 for harvested products.
- The Court of Appeals affirmed the decision but modified the damages to start from 1948.
Present Action:
- The plaintiffs filed this case to recover expenses for clearing, cultivating, and planting trees, claiming they were possessors in good faith.
- The defendants moved to dismiss, arguing that the prior judgment in Civil Case No. 4835 barred the present action.
Issue:
- Whether the present action is barred by the prior judgment in Civil Case No. 4835 under the principle of res judicata.
- Whether the plaintiffs, as intervenors in the prior case, could have raised their claims for damages in that case.
- Whether the plaintiffs, as possessors in good faith, are entitled to reimbursement for the expenses incurred in improving the land.
Ruling:
The Court affirmed the dismissal of the complaint, holding that:
- The present action is barred by the prior judgment in Civil Case No. 4835 due to the identity of parties, subject matter, and cause of action.
- The plaintiffs, as intervenors in the prior case, could have raised their claims for damages in that case, either as a counterclaim or alternatively, without weakening their claim of ownership.
- The award of damages to Fausto Aguilar in the prior case negates the plaintiffs' claim of being possessors in good faith entitled to reimbursement.
Ratio:
Res Judicata: The principle of res judicata applies when there is identity of parties, subject matter, and cause of action between the prior and present cases. Here, all three elements were present, as the plaintiffs were intervenors in the prior case, the subject matter was the same parcel of land, and the cause of action involved ownership and possession.
Alternative Claims: Under Section 9, Rule 15 of the Rules of Court, a party may set forth alternative or hypothetical claims. The plaintiffs could have asserted their claim of ownership and, alternatively, their right to reimbursement as possessors in good faith in the prior case.
Possession in Good Faith: The award of damages to Fausto Aguilar in the prior case is inconsistent with the plaintiffs' claim of being possessors in good faith. A possessor in good faith cannot simultaneously claim ownership and seek reimbursement for improvements if the court has already ruled against their ownership.