Case Digest (G.R. No. L-25051)
Facts:
- Jose B. Roxas and Venancia B. Roxas are the plaintiffs-appellees.
- Defendants-appellants include Pedro Bermudez, Dominga Martin, and Mr. & Mrs. Loreta Bermudez.
- The case originated on December 4, 1957, with a complaint filed by Pedro and Loreta Bermudez in the Court of First Instance of Manila (Civil Case No. 34498).
- The complaint claimed ownership of a parcel of land (Lot 13, Block 16-A on subdivision plan Psd-3231) fraudulently transferred to Dominga Martin by Estela Martinez Andrade and Joaquin Andrade.
- Plaintiffs alleged that the Andrades deceived Dominga Martin into signing an Affidavit of Adjudication and a deed of sale, leading to the land being registered in her name.
- The Andrades later sold the land to the Roxas spouses, who were also named as defendants in the original case.
- Plaintiffs sought damages of P6,000.00 for the alleged fraudulent acts.
- Dominga Martin intervened to seek her own damages.
- The Andrades counterclaimed for damages due to malicious prosecution.
- After a lengthy trial, the court dismissed all complaints and counterclaims on June 1, 1962.
- The plaintiffs' motion for reconsideration was denied, and they failed to appeal due to non-payment of fees, resulting in a final judgment on February 19, 1963.
- The Roxas spouses filed a new complaint (Civil Case No. 53732) to recover possession of the same land, asserting ownership based on a valid title.
- The defendants requested to file a third-party complaint against the Andrades, which the trial court denied.
- The court ruled in favor of the Roxas spouses, citing res judicata, and ordered the defendants to vacate the property and pay damages.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the trial court did not err in declaring that the decision in Civil Case No. 34498 constitutes res judicata in the present case.
- The Supreme Court also ruled that th...(Unlock)
Ratio:
- The Supreme Court affirmed the trial court's decision, noting that the previous case was decided on the merits with proper jurisdiction over the parties and subject matter.
- The issue of land ownership was central to both cases, and the claim for damages in the earlier case was linked to the ownership issue.
- The Roxas spouses established owne...continue reading
Case Digest (G.R. No. L-25051)
Facts:
The case involves Jose B. Roxas and Venancia B. Roxas as plaintiffs-appellees against defendants-appellants Pedro Bermudez, Dominga Martin, and Mr. & Mrs. Loreta Bermudez. The events leading to this case began on December 4, 1957, when Pedro and Loreta Bermudez filed a complaint in the Court of First Instance of Manila, designated as Civil Case No. 34498. They claimed ownership of a parcel of land (Lot 13, Block 16-A on subdivision plan Psd-3231) that had been fraudulently transferred to Dominga Martin, their mother, by Estela Martinez Andrade and her husband, Joaquin Andrade. The plaintiffs alleged that the Andrades deceived Dominga Martin into signing an Affidavit of Adjudication and a deed of sale, which resulted in the land being registered in her name. The Andrades subsequently sold the land to the Roxas spouses, who were also named as defendants in the original case.
In the original case, the plaintiffs sought damages amounting to P6,000.00 for the alleged fraudulent acts. Dominga Martin later intervened, seeking her own damages. The Andrades denied the allegations and counterclaimed for damages due to malicious prosecution. After a lengthy trial, the court dismissed the complaints and counterclaims on June 1, 1962. The plaintiffs' motion for reconsideration was denied, and they failed to appeal due to non-payment of fees, leading to a final judgment on February 19, 1963.
Subsequently, the Roxas spouses filed a new complaint (Civil Case No. 53732) to recover possession of the same la...