Case Summary (G.R. No. 157605)
Procedural History
The case began when the respondent filed a Complaint for Recovery of Ownership and Possession with Damages against the petitioners in October 1992 (Civil Case No. 673). The Regional Trial Court (RTC) ruled in favor of the petitioners on November 6, 1995. However, the Court of Appeals reversed this decision on September 25, 1997, declaring the respondent as the rightful owner and ordering the petitioners to vacate the property. This decision became final and executory after being upheld by the Supreme Court.
Petition for Just Compensation
In July 1999, the petitioners initiated a new complaint (Civil Case No. 1090) against the respondent, seeking just compensation for improvements made on the land, arguing they were builders in good faith. The petitioners acknowledged the previous Court of Appeals decision but contended that they should be compensated for their constructions before any demolition occurred.
Motion to Dismiss and Original Rulings
The respondent filed a Motion to Dismiss, asserting that the petitioners' new complaint was barred by res judicata, which the RTC initially denied in August 1999. However, the RTC later reversed its decision on February 16, 2000, ruling that the previous Court of Appeals decision had established the petitioners as builders in bad faith. Consequently, the RTC dismissed the petitioners' complaint.
Affirmation by the Court of Appeals
The Court of Appeals affirmed the RTC’s dismissal, holding that the principles of res judicata applied. The petitioners contested that since the motion to dismiss had been previously denied, they were preventively barred from further motioning for dismissal based on res judicata during a preliminary hearing, which they argued was procedurally improper.
Legal Analysis of Res Judicata
The Supreme Court delineated two aspects of res judicata: "bar by prior judgment" and "conclusiveness of judgment." The Court explained that the latter was applicable, stating that when an issue has been resolved in a prior case between the same parties, it serves as conclusive evidence in subsequent cases. The Supreme Court then emphasized that the petitioners' complaint was barred since the issue of possession and ownership was settled in the earlier case.
Findings on Ownership and Bad Faith
The initial ruling by the Court of Appeals noted that the petitioners had acknowledged their lack of
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Case Overview
- The case involves a Petition for Review under Rule 45, focusing on whether the complaint was barred by the principle of res judicata.
- The ruling of the Court of Appeals was affirmed by the Supreme Court, confirming that res judicata applies in this instance.
Antecedent Facts
- The dispute centers on a 703 square meter parcel of land located in Ilagan, Isabela.
- On October 29, 1992, Jaime Estenor, as the plaintiff, filed a Complaint for Recovery of Ownership and Possession with Damages against the petitioners.
- The case was tried as Civil Case No. 673 in the Regional Trial Court (RTC) of Ilagan, Isabela, Branch 16.
- The RTC ruled in favor of the petitioners on November 6, 1995.
- Jaime Estenor appealed to the Court of Appeals (CA-G.R. No. 52338), which reversed the RTC decision on September 25, 1997, declaring Estenor the rightful owner and ordering petitioners to vacate the land.
Court of Appeals Decision
- The appellate court's dispositive portion mandated:
- Reversal of the RTC decision.
- Declaration of Estenor as the land's owner.
- Order for the petitioners to vacate and pay compensation of P300.00 per month from June 1991 until vacation, alongside attorney's fees and litigation expenses.
- The appellate decision became final and executory after a certiorari petition was dismissed by the Supreme Court.
Subsequent Developments
- Following the appellate decision, a Writ of Execution and Demolition was issued against the petitioners.
- On July 6, 1999, the petitioners filed a new Complaint for just compensation and a temporary restraining order, registered a