Case Digest (G.R. No. L-25450)
Facts:
On March 19, 1959, eleven brothers and sisters, all surnamed Allanigue, filed Civil Case No. 217-R in the Court of First Instance of Rizal against their sister Lorenza Allanigue, her husband Simeon Santos, and others for partition and annulment of conveyances of a 360-square-meter lot in San Dionisio, Paranaque. Defendants were declared in default, the trial court ordered partition and issued a writ of execution; Leonardo Santos, son of Simeon and Lorenza and owner of a house on the lot though not an original defendant, filed a third-party claim and a motion to recall the writ which the court denied, and on March 15, 1962 the court ordered demolition of the houses on the lot.
On April 2, 1962 Leonardo Santos and the defendants petitioned this Court in G.R. No. L-19618, which the Supreme Court denied on February 28, 1964; after that decision became final the trial court, on plaintiffs' motion, ordered demolition of Leonardo Santos' house by order dated December 9, 1965, and he filed the present petition for certiorari and prohibition challenging the demolition order.
Issues:
- Did the Court of First Instance have jurisdiction to order the demolition of Leonardo Santos' house?
- Is Leonardo Santos precluded from challenging the demolition by being a successor-in-interest of his parents and by the prior Supreme Court judgment in G.R. No. L-19618?
Ruling:
The Court denied the petition for certiorari and prohibition and dissolved the writ of preliminary injunction, with treble costs against the petitioner. The Court held that the trial court had jurisdiction to order demolition and that Leonardo Santos was bound by the prior judgment and decision.
Ratio:
The Court found that Leonardo Santos claimed under his parents, successors who were parties in Civil Case No. 217-R, and therefore he was bound by the judgment against them; his registered purchase did not alter that result. Because he rebuilt and enlarged his house after his predecessors had been summoned in 1959, he was a builder in bad faith and lost the improvement without right to indemnity under Article 449 of the Civil Code, while the landowners could elect demolition at the builder's expense under Article 450 of the Civil Code, which they chose. The prior Supreme Court decision in G.R. No. L-19618 was on the merits, became final, involved the same subject-matter and cause of action, and therefore operated as res judicata to bar the present challenge to the demolition order.
Doctrine:
- A successor-in-interest who claims under predecessors is bound by judgments rendered against those predecessors.
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