Sto. Domingo v. Sto. Domingo
REITERATIONFacts
The Antecedents: Raymundo Sto. Domingo contracted two marriages. His first marriage produced Urbana Sto. Domingo, and his second marriage with Pilar Evangelista produced Leoncia Sto. Domingo. Before his death on May 1, 1935, Raymundo executed a deed of donation of his properties in favor of Urbana, who accepted and took possession. After Raymundo's death, his heirs were Urbana, Leoncia, and Pilar (Leoncia's mother). Procedural History: - First Case (August 28, 1936): Pilar Evangelista, individually and as guardian ad litem for minor Leoncia, filed Civil Case No. 5315 against Urbana and Deogracias Matias, seeking to annul the donation and a subsequent sale of the donated properties by Urbana to Matias, alleging they were fictitious and void. The case was settled amicably, with Pilar receiving P1,000.00. The court approved the settlement and dismissed the case. - Second Case (October 7, 1938): Twenty-two months later, Pilar (now married to Aquilino Robles), again individually and as guardian ad litem for Leoncia, filed another action for the annulment of the same donation and sale against the same defendants. This case was dismissed upon the plaintiffs' motion for not being ready for trial, but without prejudice to revival. - Third Case (February 22, 1954): Severino Alberto, appointed administrator of Raymundo Sto. Domingo's estate, filed a complaint against Urbana and Matias for the annulment of the donation and sale, alleging fraud and lack of consideration. This case was dismissed on the ground of the administrator's lack of legal capacity to sue. - Present Case: The current action was instituted by Pilar, individually and as guardian ad litem for Leoncia, against the same defendants, seeking the annulment of the same deed of donation and sale on the same grounds of fraud and lack of consideration. The defendants moved to dismiss, citing prescription and bar by prior judgment. The trial court granted the motion and dismissed the complaint. The Petition: Plaintiffs appealed the dismissal of their complaint to the Court of Appeals, which was certified to the Supreme Court due to the involvement of only questions of law.
Issue(s)
Whether the present action is barred by a prior judgment. Whether a compromise settlement approved by the court, involving a minor represented by a guardian ad litem, binds the minor and precludes a subsequent suit on the same cause of action. Whether the cause of action has prescribed.
Ruling
The appeal is dismissed. The order of the Court of First Instance of Bulacan is affirmed.
Ratio Decidendi
On the issue of bar by prior judgment: The Court held that the present case is barred by the prior judgment rendered in Civil Case No. 5315. This conclusion is inescapable because the present case involves the same parties and the same issues as those litigated and settled in the first case. The first case was instituted by Pilar Evangelista, individually and as guardian ad litem for her minor daughter Leoncia, against the same defendants, seeking the annulment of the same deed of donation and sale. The settlement in that case was amicably reached, approved by the court, and became final for lack of appeal. The subsequent filing of a second case by the same plaintiffs, which was also dismissed, further reinforces the finality of the issues presented. On the effect of the compromise settlement involving a minor: The Court clarified that the fact that one of the party-litigants is a minor does not negate the binding effect of the compromise settlement. The minor, Leoncia, was represented by her guardian ad litem, Pilar Evangelista, which is recognized by the Rules of Court. The rule is well-settled that a compromise settlement, when considered and sanctioned by the court, and rendered on testimony in addition to the admission or confession of the guardian ad litem, will not be set aside in the absence of fraud in its procurement. While ordinarily a guardian ad litem's authority is restricted to matters connected with the litigation and cannot bind the infant or their estate without court approval, in this case, the settlement was explicitly approved by the court, thereby validating the guardian ad litem's actions. On the issue of prescription: Although the defendants raised prescription as a ground for dismissal, the Court found it unnecessary to delve into this issue extensively, as the case was already barred by prior judgment. The principle of res judicata, stemming from the court-approved compromise in the first case, effectively precluded the filing of any subsequent action on the same subject matter between the same parties, regardless of whether the period for prescription had lapsed.
Main Doctrine
A compromise settlement approved by the court, even if involving a minor represented by a guardian ad litem, constitutes res judicata and bars a subsequent action between the same parties on the same issues.