Case Summary (G.R. No. L-27388)
Procedural History
The plaintiffs initiated Civil Case No. 4731 in the Court of First Instance of Davao on July 2, 1965, with a complaint seeking to declare the aforementioned deeds of sale as fraudulent and void. The defendants moved to dismiss this complaint, citing the statute of limitations and laches, resulting in its dismissal on October 23, 1965. Subsequently, on November 5, 1965, the plaintiffs filed Civil Case No. 4856, which mirrored the original complaint but with slightly altered wording. The defendants again moved to dismiss this second complaint on the grounds of res judicata based on the prior dismissal.
Issue of Res Judicata
The primary issue presented in this appeal is whether Civil Case No. 4856 is barred by the order of dismissal in Civil Case No. 4731. The Court determined that, given the first case's dismissal was not without prejudice and was on the merits, the order holds res judicata consequences. Important factors considered include the identity of parties, the subject matter, and the cause of action.
Identity of Parties and Cause of Action
Both cases involve the same parties and the same factual circumstances surrounding the execution of the deeds of sale. The claim is premised on the assertion that these deeds were fraudulent, resulting in a detriment to the plaintiffs as heirs. The Court noted that the evidence supporting both actions would be identical, as both sought to address the same alleged wrongdoings by the defendants.
Argument Against Amendments
The plaintiffs argued that the lower court erred by dismissing the complaint in the second case, claiming an entitlement to amend their original complaint from Case No. 4731. The Court rejected this argument, indicating that any desire to amend should have been pursued in the context of Case No. 4731 itself. Having failed to appeal the order dismi
...continue readingCase Syllabus (G.R. No. L-27388)
Introduction to the Case
- The case involves plaintiffs Trinidad Rasay-Lahoz, Remedios Rasay-Nepomuceno, Iluminada Rasay-Jocson, Josefina Rasay-Mauck, Edelwina Rasay, and Cenon Rasay who seek to reverse the dismissal of their complaint by the Court of First Instance of Davao.
- The defendants in this case are Domingo Leonor, Juliana R. de Leonor, and Francisco Leonor.
- The plaintiffs filed their original complaint in Civil Case No. 4731 on July 2, 1965, and subsequently filed a second, nearly identical complaint in Civil Case No. 4856 on November 5, 1965.
Background of the Case
- The plaintiffs contended that two deeds of sale, executed on May 10, 1956, and May 18, 1956, were fraudulent and fictitious.
- The first deed was executed by Juliana R. de Leonor in favor of Elena R. Ledesma, while the second was executed by Ledesma in favor of Francisco Leonor.
- Plaintiffs sought the declaration of these deeds as "null and void" and requested the reconveyance of the land, alongside damages and attorney's fees.
Dismissal of Civil Case No. 4731
- The defendants moved to dismiss the original complaint in Case No. 4731, citing the statute of limitations and laches.
- The Court granted the motion on October 23, 1965, dismissing the complaint based on the prescription of action.
Filing of Civil Case No. 4856
- The plaintiffs filed Civil Case No. 4856, which mirrored the original complaint but included a slight variation in the phrasing regardin