Title
Yulo vs. Yang Chiao Seng
Case
G.R. No. L-12541
Decision Date
Mar 30, 1960
Rosario Yulo sought to reopen a case, claiming a partnership with Yang Chiao Seng, but the Supreme Court ruled their relationship was a sublease, not a partnership, and denied the motion due to lack of *res judicata* elements.

Case Summary (G.R. No. L-12541)

Procedural Background

The matter arises from a "Petition to Reopen Case," which was presented by the appellants on December 14, 1959. The petition alleges that prior rulings from the Court of Appeals established a partnership between Rosario U. Yulo and Yang Chiao Seng concerning the construction of the Astor Theatre. Each party claims this ruling affects the current litigation regarding their relationship.

Original Court Ruling

The Court of Appeals' earlier decision referenced by the appellants involved an ejectment case brought by plaintiffs Emilia and Maria Carrion Sta. Marina against Yulo and Seng. The key issue in that case was determining the reasonable rental value of the occupied property, with differing evaluations presented by both parties. The Court concluded that the amount claimed by the plaintiffs represented Yulo’s profit share from what had been characterized as a partnership, rather than a mere rental value—which became a crucial point in later arguments.

Res Judicata Analysis

The court thoroughly examined whether res judicata applied to this case, ultimately concluding that it did not. The legal doctrine of res judicata mandates that only parties to a judgment are bound by it in subsequent related controversies. Here, the original action involved different plaintiffs and defendants, focusing on different legal issues—namely, ejectment versus partnership claims. Thus, the criteria for res judicata, including the identity of parties, issues, and causes of action, were not satisfied.

Conclusion on Legal Relationship

The court asserted that no partnership existed between Yulo and Seng based

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