Case Digest (G.R. No. 101883)
Facts:
- Spouses Lydia and Virgilio Meliton (petitioners) filed a case against the Court of Appeals and Nelia A. Ziga, represented by her Attorney-in-Fact Ramon A. Arejola (respondents).
- On June 22, 1988, Nelia Ziga filed a complaint for rescission of a lease contract against Lydia Meliton in the Regional Trial Court (RTC) of Naga City, Branch 27, docketed as Civil Case No. RTC 88-1480.
- Grounds for rescission included:
- Failure to deposit one month's rental.
- Non-payment of monthly rentals.
- Unauthorized construction of a concrete wall and roof.
- Unauthorized sublease of the property.
- Lydia Meliton denied the allegations and counterclaimed for damages due to the demolition of her kitchenette and improvements, totaling P34,000.00, P10,000.00, and P23,000.00, respectively, plus moral damages, attorney's fees, and litigation expenses.
- On May 29, 1989, the trial court dismissed the complaint as moot due to the lease's expiration and dismissed the counterclaims for non-payment of docket fees.
- On December 6, 1989, the Melitons filed a new complaint for the same amounts in Civil Case No. RTC 89-1942.
- Respondents moved to dismiss the new case, arguing it was barred by the prior judgment.
- The trial court denied the motion, stating the dismissal of the counterclaims was not on the merits.
- The Court of Appeals annulled the trial court's orders and dismissed the new complaint, leading to the present appeal.
Issue:
- (Unlock)
Ruling:
- Yes, the counterclaims of the petitioners were compulsory in nature.
- No, the petitioners are not barred from asser...(Unlock)
Ratio:
- The Supreme Court held that the counterclaims were compulsory because they arose from the same transaction or occurrence as the original complaint, specifically the lease contract.
- The counterclaims were logically related to the complaint for rescission of the lease due to alleged breaches by the lessee.
- The rights and obligations of both parties emanated from the same contractual relationship, making the counterclaims compulsory.
- The dismissal of the counterclaims for non-payment of docket fees did not constitute an adjudication on the merits.
- Th...continue reading
Case Digest (G.R. No. 101883)
Facts:
The case involves Spouses Lydia and Virgilio Meliton (petitioners) against the Court of Appeals and Nelia A. Ziga, represented by her Attorney-in-Fact Ramon A. Arejola (respondents). On June 22, 1988, Nelia Ziga filed a complaint for rescission of a lease contract against Lydia Meliton in the Regional Trial Court (RTC) of Naga City, Branch 27, docketed as Civil Case No. RTC 88-1480. The grounds for rescission included Meliton's failure to deposit one month's rental, non-payment of monthly rentals, unauthorized construction of a concrete wall and roof, and unauthorized sublease of the property. Lydia Meliton filed an answer denying the allegations and set up counterclaims for damages due to the demolition of her kitchenette and improvements, totaling P34,000.00, P10,000.00, and P23,000.00, respectively, plus moral damages, attorney's fees, and litigation expenses. On May 29, 1989, the trial court dismissed the complaint as moot due to the lease's expiration and dismissed the counterclaims for non-payment of docket fees. Subsequently, on December 6, 1989, the Melitons filed a new complaint for the same amounts in Civil Case No. RTC 89-1942. The respondents moved to dismiss this new case, arguing it was barred by the prior judgment. The trial court denied the motion, stating the ...