Title
Roxas vs. Bermudez
Case
G.R. No. L-25051
Decision Date
Sep 30, 1968
The court confirms that a prior ruling on land ownership is conclusive and prohibits the introduction of a third-party complaint.
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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

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