Facts:

• The case involves Nicanor T. Santos (petitioner) and his sister Consuelo T. Santos-Guerrero, along with her husband Andres Guerrero (respondents).
• Both parties are heirs of the deceased Urbano Santos and Candelaria Santos.
• In 1956, Nicanor, Consuelo, and eight other siblings executed a "Basic Agreement of Partition" for their inherited properties.
• In 1958, Consuelo and her husband filed a lawsuit against Nicanor and two other brothers in the Court of First Instance (CFI) of Rizal to validate the 1956 Agreement of Partition.
• While the case was pending, the Santos heirs executed a "Deed of Partition (With More Corrections)" on May 5, 1959, dividing the properties into four shares.
• Nicanor received Share No. 3 and was obligated to pay Consuelo P31,825.00.
• The Guerreros filed another complaint against Nicanor for recovery of Consuelo's share under the 1959 Deed of Partition, leading to the consolidation of Civil Case No. 4871 and Civil Case No. 5858.
• On November 27, 1960, Judge Andres Reyes ordered Nicanor to pay Consuelo P26,650.00.
• On December 28, 1979, Judge Eutropio Migriño ordered Nicanor to pay Consuelo P31,825.00, plus damages and attorney's fees.
• Nicanor appealed, and the decision was affirmed by the Intermediate Appellate Court (IAC) and later by the Supreme Court.
• The Guerreros did not pursue execution for over six years and filed a complaint for revival of the 1979 decision on June 3, 1992, as Civil Case No. 1784-MN in the Regional Trial Court of Malabon-Navotas.
• Nicanor filed a motion to dismiss, citing res judicata and lack of earnest settlement efforts.
• The RTC initially dismissed the complaint but later revived the 1979 judgment on July 27, 1995.
• Nicanor appealed to the Court of Appeals, which dismissed his appeal on March 24, 1998.
• Nicanor then filed a petition for review on certiorari to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Court of Appeals did not err in its ruling regarding the inapplicability of Article 222 and Section 1(j), Rule 16.
• The December 28, 1979 decision was not null and void due to res judicata.
• The act...(Unlock)

Ratio:

• The Supreme Court affirmed the Court of Appeals' decision, highlighting that family lawsuits often lead to deeper conflicts, necessitating earnest settlement efforts as a prerequisite for maintaining an action.
• The Court noted that while the complaint did not explicitly allege such efforts, the introduction of evidence could remedy this defect.
• The revival of a dormant judgment does not fall under Ar...continue reading