Case Digest (G.R. No. 62341)
Facts:
Jorge Wee Sit and Lucia Wee Sit sought certiorari against Honorable Omar U. Amin, District Judge of the Court of First Instance, Branch III, Zamboanga City, assailing the dismissal of their amended complaint for quieting of title (originally for recovery of house or value) and the denial of their motion for reconsideration. The controversy over Lot 651-A arose from an “Amended Compromise Agreement” dated February 9, 1976, where Atty. Jesus Aquino received the lot for his attorney’s fees, while the Wee Sit spouses were granted limited rights over residence and related uses for two years, with the court approving the compromise on March 20, 1976.After the two-year period, Jesus Aquino sued for ejectment against Jorge Wee Sit; judgment ordering vacating was affirmed and became final on February 15, 1981. While the ejectment case was pending, the Wee Sit heirs filed Civil Case No. 2300 to recover Lot 651-A; it was dismissed on October 16, 1980 on res judicata, and petitioners’ sub
Case Digest (G.R. No. 62341)
Facts:
- Parties and their interests in Lot 651-A
- Petitioners Jorge Wee Sit and Lucia Wee Sit sought to quiet title over Lot 651-A and the house used as residence on the lot.
- Respondents were Honorable Omar U. Amin, District Judge, Court of First Instance, Branch III, Zamboanga City; and private respondents Jesus Aquino and Carmen Benito.
- Origin of the dispute: Amended Compromise Agreement in Special Case No. 21 (971)
- In Case No. 21 (971) of the Court of First Instance of Zamboanga City Branch II, an “Amended Compromise Agreement” dated February 9, 1976 was reached.
- Under the agreement, private respondent Jesus Aquino was ceded Lot 651-A, located on Canelar Street, Zamboanga City, and more particularly described in Transfer Certificate of Title No. T-31207.
- The cession in favor of Jesus Aquino was made in full and complete settlement of Jesus Aquino’s claim for ten percentum (10%) of the estate of the late Juan S. Wee Sit, representing honorarium or attorney’s fees, and it received court approval.
- Salient terms of the Amended Compromise Agreement (February 9, 1976)
- The agreement acknowledged that although Lot 651-A had been ceded to Atty. Aquino by dacion in payment judicially approved, Mrs. Lucia Hao Vda. de Wee Sit and her children were granted occupation of the house on the lot without payment of rental for two years from the date of the agreement.
- For sentimental reason, if Mrs. Lucia Hao Vda. de Wee Sit chose to remain on the house, the right to remain was granted during her lifetime free from any rental whatsoever.
- If and when Mrs. Lucia Hao Vda. de Wee Sit vacated the premises, she was entitled to remove the materials of the house, fences, and other improvements without paying Atty. Aquino.
- Atty. Aquino authorized Mrs. Lucia Hao Vda. de Wee Sit to collect rentals due from tenants who erected buildings on Lot 651-A within two years from today; the collections would be her personal property and she would not be obliged to account to Atty. Aquino.
- Atty. Aquino granted free payment of the real property tax on Lot 651-A for the two-year period; Atty. Aquino would pay all real property tax without any obligation on Mrs. Lucia Hao Vda. Wee Sit to contribute.
- Real property taxes accrued before the agreement date would be paid by Atty. Aquino without obligation on the part of the estate of the late Juan S. Wee Sit or Mrs. Lucia Hao Vda. de Wee Sit to refund, reimburse, or contribute.
- Expenses, materials, taxes, documentary stamps, science fund stamps, registration, and similar costs in the transfer of Lot 651-A would be borne by Atty. Aquino without obligation on the part of the estate or Mrs. Lucia Hao Vda. de Wee Sit to refund, reimburse, or contribute.
- The heirs accepted the beneficence and expressed gratitude for Atty. Aquino’s liberality.
- Approval and effect of the Amended Compromise Agreement
- The Court approved the agreement upon finding that it was not contrary to law, morals, good customs, public order, or public policy, and that it would redound to the best interest of the estate.
- The approval order provided that the agreement was approved as “full and complete settlement” of the claims of Atty. Jesus A. Aquino against the estate of the late Juan S. Wee Sit.
- The order directed the Register of Deeds of Zamboanga City to cancel annotations on other certificates of title and to cancel Transfer Certificate of Title No. T-31,207, issuing a new one in the name of Atty. Jesus Aquino, married to Carmen Benito, with full faith and credit.
- Ejectment litigation based on non-compliance: Special Case No. 2689 (261) and related proceedings
- After a period of two (2) years from March 20, 1976, Jesus Aquino filed a complaint for ejectment against Jorge Wee Sit for failure to comply with the terms of the agreement.
- The case was docketed as Special Case No. 2689 (261) of the City Court of Zamboanga.
- A decision was rendered in favor of Jesus Aquino, ordering Jorge Wee Sit to vacate.
- On appeal to the Court of First Instance of Zamboanga, the City Court decision was affirmed.
- The judgment became final on February 15, 1981.
- A petition for review by certiorari brought by Jorge Wee Sit to the Supreme Court was denied for lack of merit in resolutions dated May 13, 1981 and July 15, 1981.
- Attempt to recover Lot 651-A: Civil Case No. 2300
- While the ejectment case was pending, on February 22, 1980, Jorge Wee Sit, Lucia Wee Sit, and Antonio Wee Sit filed a complaint against Jesus Aquino and Carmen Aquino in the Court of First Instance of Zamboanga.
- The complaint sought to recover Lot 651-A and was docketed as Civil Case No. 2300.
- The Court of First Instance dismissed the complaint in an order dated October 16, 1980.
- The dismissal rested on the finding that the subject matter had been compromised by the parties in the amended compromise agreement dated February 9, 1976, which had been approved by the court on March 20, 1976.
- The lower court ruled that the compromise agreement constituted res judicata between the parties and could no longer be set aside and/or annulled, and it dismissed the complaint for failure to state a cause of action.
- Supreme Court review of Civil Case No. 2300 dismissal: G.R. No. 56112
- The plaintiffs in Civil Case No. 2300 filed a motion for reconsideration, which the trial court denied.
- Plaintiffs then filed before the Supreme Court a petition (G.R. No. 56112) seeking to review by certiorari the trial court’s ruling.
- The Supreme Court dismissed the petition in a resolution dated February 10, 1982.
- Subsequent motions for reconsideration, including a supplemental motion and a second supplemental motion, were filed and were all denied in resolutions dated July 14, 1982 and in another resolution dated September 22, 1982, for lack of merit.
- The resolution dated ...(Subscriber-Only)
Issues:
- Whether the trial court erred in dismissing petitioners’ amended complaint for quieting of title (and originally for recovery of the house or value thereof) on the ground of res judicata
- Whether there were two (2) final judgments on the merits rendered by courts of competent jurisdiction that barred the present action.
- Whether there was identity of subject matter, involving the same lot (Lot 651-A) and the house within the premises.
- Whether there was identity of parties, involving the heirs of Juan Wee Sit and spouses Jesus Aquino and Carmen Aquino.
- Whether there was identity of cause of action, considering petitioners’ claim that while they admitted the ownership of Lot 651-A by private respondents, they retained ownership of the house within the premises.
- Whether the trial court’s finding that petitioners were bound by the terms and approval of the Amended Compromise Agreement was legally err...(Subscriber-Only)
Ruling:
- (Subscriber-Only)