Case Digest (G.R. No. L-5078)
Facts:
- Luis Francisco is the plaintiff and appellant.
- Defendants and appellees include Maxima Vda. de Blas and others.
- The dispute involves Cadastral Lot No. 2464-A in Caloocan, Rizal, owned by Francisco.
- The lot is bordered by land owned by Manuel Syjuco and Martin Syjuco to the North, and by Maxima Vda. de Blas to the South, which includes Cadastral lots Nos. 2464-D and 2465.
- Jose Apolonio's land is adjacent to Maxima Vda. de Blas's property to the South.
- On June 27, 1950, Manuel and Martin Syjuco filed Civil Case No. 287 against Francisco, claiming a 10-meter by 1-meter strip of land.
- On February 22, 1951, Maxima Vda. de Blas filed Civil Case No. 1372 against Francisco, claiming a 12.85 square meter strip of land.
- Francisco admitted to occupying the disputed strips but asserted ownership as part of his registered lot.
- Instead of proceeding with the two cases, Francisco filed a separate action on March 31, 1951, to remove a "cloud" on his title.
- He included Jose Apolonio as a defendant, alleging that Apolonio's title encroached on Maxima Vda. de Blas's property.
- Apolonio claimed the changes to his lot's description were lawful and consented to by Francisco or his predecessors.
- The other defendants moved to dismiss the complaint, citing the pendency of the two earlier actions.
- The court granted the motion to dismiss, leading Francisco to appeal.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the dismissal of the complaint against the other defendants.
- It ruled that there was an identity of parties, causes of action, and relief among the three cases. ...(Unlock)
Ratio:
- The Court's reasoning was based on the principles of res judicata, which require identity of parties, causes of action, and relief for a prior judgment to bar a subsequent action.
- The parties in the first two actions were the same as in Francisco's third action.
- The core issue across all three cases was ownersh...continue reading
Case Digest (G.R. No. L-5078)
Facts:
The case involves Luis Francisco as the plaintiff and appellant against Maxima Vda. de Blas and others as defendants and appellees. The dispute centers around a parcel of land identified as Cadastral Lot No. 2464-A, located in Caloocan, Rizal, which is owned by Luis Francisco. This lot is bordered to the North by land owned by Manuel Syjuco and Martin Syjuco, and to the South by land owned by Maxima Vda. de Blas, which includes Cadastral lots Nos. 2464-D and 2465. Additionally, the land of Jose Apolonio lies adjacent to Maxima Vda. de Blas's property to the South.
On June 27, 1950, Manuel Syjuco and Martin Syjuco initiated a legal action against Luis Francisco in the Court of First Instance of Rizal (Civil Case No. 287), seeking to recover a strip of land measuring 10 meters by 1 meter, which they claimed was part of Francisco's lot and was illegally occupied by him. Subsequently, on February 22, 1951, Maxima Vda. de Blas filed a similar suit (Civil Case No. 1372) against Francisco, claiming a strip of land measuring 12.85 square meters, also alleged to be part of Francisco's lot and illegally occupied.
In response to these complaints, Luis Francisco admitted to occupying the disputed strips but asserted ownership over them as part of his registered lot. Instead of proceeding to trial in the two pending cases, Francisco filed a separate action on March 31, 1951, seeking to remove what he termed a "cloud" on his title caused by the claims of the Syjuco brothers and Maxima Vda. de Blas. He included Jose Apolonio as a defendant, alleging that ...