Title
Juan vs. Go Cotay
Case
G.R. No. 7785
Decision Date
Dec 22, 1913
Plaintiffs sued defendants for non-delivery of palay; first case sought specific performance, second sought rescission. Court ruled second action barred by res judicata, as first judgment resolved all claims.
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Case Digest (G.R. No. 7785)

Facts:

  1. Parties and Claims:

    • Plaintiffs: Felipe Juan and Faustina Chu-Ongco.
    • Defendants: Go Cotay et al.
    • The plaintiffs filed two actions against the defendants.
  2. First Action:

    • Filed in the justice of the peace court.
    • Alleged that plaintiffs purchased 203 cavanes of palay from defendants for P398.75.
    • Plaintiffs paid the amount but defendants failed to deliver the palay.
    • Plaintiffs sought delivery of the palay or its value in money, plus damages and costs.
    • Judgment was rendered in favor of the plaintiffs for P398.75.
    • On appeal to the Court of First Instance, the judgment was reversed, and defendants were absolved.
  3. Second Action:

    • Filed in the Court of First Instance.
    • Same allegations as the first action regarding the purchase and non-delivery of palay.
    • Plaintiffs sought:
      (1) Rescission of the contract;
      (2) Return of P398.75;
      (3) Damages of P310.25 and costs.
  4. Key Issue:

    • Whether the judgment in the first action operates as res judicata, barring the second action.
  5. Plaintiffs' Argument:

    • The first action was for specific performance, while the second is for rescission and damages.
    • Cited Article 1124 of the Civil Code, which allows a party to choose between specific performance or rescission with damages.
  6. Defendants' Position:

    • The second action is barred by res judicata because the subject matter and parties are identical to the first action.

Issue:

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Ruling:

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Ratio:

  1. Res Judicata Applies:

    • The first and second actions involved the same parties, subject matter, and claims.
    • The plaintiffs' prayer for alternative relief (specific performance or rescission with damages) in the first action encompassed all issues raised in the second action.
    • The courts in the first action acted within their jurisdiction, and their judgment is final and conclusive.
  2. Article 1124 of the Civil Code:

    • While Article 1124 allows a party to choose between specific performance or rescission, the plaintiffs' claim in the first action already included both remedies.
    • The plaintiffs cannot relitigate the same matter under a different legal theory after losing in the first action.
  3. Finality of Judgments:

    • The principle of res judicata ensures finality in litigation and prevents endless disputes over the same issue.
    • To allow the second action would undermine the respect for final judgments and the stability of legal rights.


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