Title
Escudero vs. Flores
Case
G.R. No. L-7401
Decision Date
Jun 25, 1955
The court upheld the original judgment against the Escuderos’ annulment attempt, citing res judicata and the absence of a duty to disclose by the Flores heirs.
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Case Digest (G.R. No. L-7401)

Facts:

  • Arsenio Escudero and others (plaintiffs/appellants) vs. Gertrudo Flores and others (defendants/appellees).
  • Originated from Civil Case No. 9296, where the Flores heirs sued the Escuderos for land recovery.
  • The Laguna Court of First Instance ruled in favor of the Flores heirs, ordering the Escuderos to deliver one-sixth of the property and pay monthly rentals of P20.83 starting October 11, 1939.
  • The judgment was confirmed on appeal in March 1953.
  • On May 21, 1953, the Escuderos filed a new lawsuit to annul the previous judgment, alleging fraud by the Flores heirs regarding the concealment of their mother’s prior receipt of her share of the property.
  • The Escuderos claimed the Flores heirs had no right to the land and that their previous counsel erred in the stipulation of facts.
  • The Flores heirs filed a motion to dismiss, citing res judicata and lack of standing.
  • The trial court, led by Judge Nicasio Yatco, granted the motion to dismiss on June 30, 1953, prompting the appeal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the trial court's dismissal of the Escuderos' complaint.
  • The Court confirmed that the complaint was barred by res judicata, as the prior judgment was final and issued by a competent court.
  • The alleged fraud by the Flores heirs was deemed insufficient for annulment, being intrinsic t...(Unlock)

Ratio:

  • The decision was based on res judicata principles, preventing relitigation of issues already judicially determined.
  • The previous judgment in Civil Case No. 9296 was final, rendered on the merits with proper jurisdiction.
  • The Escuderos' fraud claim was inadequate to overturn ...continue reading

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