Title
Jalandoni vs. Martir-Guanzon
Case
G.R. No. L-10423
Decision Date
Jan 21, 1958
Plaintiffs sought partition, damages, and share of crops from 1941-1955. Court denied moral/exemplary damages, barred product claims due to prior judgment, rejected tax payment demand, and denied attorneys' fees.
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Case Digest (G.R. No. L-10423)

Facts:

  1. Initial Lawsuit (Case No. 573):

    • On January 9, 1947, plaintiffs Amado P. Jalandoni and Paz Ramos filed a lawsuit against defendants Antonio Guanzon and others.
    • The plaintiffs sought partition of several lots (Nos. 130-A, 130-B, 130-F of the Murcia Cadastre and Nos. 1288 and 1376 of the Bogo Cadastre) and recovery of damages due to the defendants' refusal to recognize their rights and partition the properties.
    • The plaintiffs also demanded an accounting and delivery of their share in the crops from 1941-1942 to 1946-1947.
  2. Decision in Case No. 573:

    • On February 22, 1955, the Court of First Instance of Negros Occidental ruled in favor of the plaintiffs, ordering the partition of the lands.
    • However, the court denied the claim for damages due to the plaintiffs' failure to prove the exact and actual damages suffered.
    • The decision became final as neither party appealed.
  3. Second Lawsuit (Case No. 3586):

    • On August 26, 1955, the plaintiffs filed a new lawsuit (Case No. 3586) seeking:
      • P20,000 as moral and exemplary damages for suffering, anguish, and anxiety caused by the defendants' refusal to partition the properties.
      • P55,258.20 as their share of the products from 1947 to 1955.
      • P4,689.54 as unpaid land taxes on the properties.
      • P2,500 for attorneys' fees.
  4. Dismissal of the Second Complaint:

    • The trial court dismissed the second complaint for failure to state a cause of action.
    • The plaintiffs' motion for reconsideration was denied, prompting them to appeal to the Supreme Court.

Issue:

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Ruling:

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Ratio:

  1. Retroactivity of Laws:

    • Provisions of the new Civil Code that impose civil sanctions or penalties for acts not penalized under the old law (Civil Code of 1899) cannot be applied retroactively. Moral and exemplary damages, introduced in the new Civil Code, fall under this rule.
  2. Res Judicata and Splitting Causes of Action:

    • A final judgment on the merits is conclusive not only on the issues actually litigated but also on all matters that could have been raised in the prior case. Claims arising from the same cause of action must be litigated in one proceeding to avoid multiplicity of suits.
  3. Tax Liability:

    • Taxes are obligations owed to the government, and private parties cannot compel payment to themselves unless they have paid the taxes to protect their interests, which was not alleged in this case.
  4. Attorneys' Fees:

    • Attorneys' fees are not recoverable unless expressly provided by law or contract. In this case, there was no legal basis for awarding attorneys' fees to the plaintiffs.


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