Jimenez v. Camara
REITERATIONFacts
1. The Antecedents: Plaintiffs, as assignees of Adriano Golez, sought to compel defendant Carmelo S. Camara to execute deeds of conveyance for 17 parcels of land. These lands, along with seven others comprising Haciendas Buenavista and Aurelia, were originally co-owned by the plaintiffs' predecessors and mortgaged to the Philippine National Bank. Following foreclosure and renunciation of redemption rights, a complex series of transactions involving Camara was initiated to facilitate the redemption of these properties from the bank. 2. Procedural History: The underlying dispute originated from a series of contracts executed in 1931, wherein Camara agreed to facilitate the redemption of 24 parcels of land from the Philippine National Bank. A subsequent lease agreement over seven of these lots was made in favor of Camara. After Camara paid the outstanding debt and acquired the properties, disputes arose regarding his obligation to reconvey them. This led to Civil Case No. 306, where Adriano Golez sued Camara for possession of the leased lots. This Court's decision in G.R. No. L-4460 established Golez's right to redeem and outlined the payment terms. Camara appealed a subsequent trial court order in that case directing the reconveyance of all 24 lots (G.R. No. L-9160), which this Court affirmed, holding Camara bound to convey all 24 lots. The present case, Civil Case No. 3364, was filed by the plaintiffs as assignees of Golez, seeking the reconveyance of the 17 lots not under lease, while Civil Case No. 306 was still pending appeal. 3. The Petition: The plaintiffs, as assignees of Adriano Golez, filed this action (Civil Case No. 3364) seeking the reconveyance of 17 specific parcels of land from Carmelo S. Camara. The lower court dismissed the complaint, ruling that the action violated the rule against splitting a cause of action, as the plaintiffs could have sought the reconveyance of all 24 lots in the prior litigation (Civil Case No. 306). The plaintiffs appealed this dismissal, arguing that the previous case concerned only the recovery of possession of the leased lots, while the current case pertains to the title of the remaining 17 lots. This Court, however, found that both actions stemmed from the same underlying transaction and contractual breaches, and importantly, that a prior decision in G.R. No. L-9160 had already definitively ruled that Camara was obligated to convey all 24 lots, rendering the present petition moot and res adjudicata.
Issue(s)
Whether the present action for reconveyance of 17 lots is barred by the rule against splitting a cause of action. Whether the present action is barred by res judicata in light of previous Supreme Court decisions concerning the same parties and contracts.
Ruling
The Supreme Court affirmed the order of dismissal issued by the Court of First Instance. The Court held that the present action is barred by the rule against splitting a cause of action and by res judicata.
Ratio Decidendi
On the issue of splitting a cause of action: The Court held that the plaintiffs' cause of action in the present case (Civil Case No. 3364) and the cause of action in the previous case (Civil Case No. 306) arose from the same delict or wrong, which was the alleged infringement of the same contract (Annex B) by the same defendant. Both complaints were founded on one and the same contract, and the rule is that where the covenant or contract is entire and the breach total, there can be only one action. The object of this rule is to prevent a multiplicity of actions, harassment of parties, and accumulation of costs. The plaintiffs' argument that the first case was for recovery of possession of 7 lots while the present case is for reconveyance of titles to 17 lots was rejected, as both contracts (Annex A and B) were part of a single transaction for the redemption of the mortgaged properties. Therefore, the present action, which could have been included in the previous suit, constitutes a splitting of a cause of action. On the issue of res judicata: The Court found that the question involved in the instant case had become moot or res judicata due to a previous Supreme Court ruling in G. R. No. L-9160 (Adriano Golez vs. Carmelo S. Camara, 101 Phil., 363). In that case, the Supreme Court had already held that Camara was bound to convey to Golez not only the interest in the seven lots constituting Haciendas Aurelia and Buenavista but also the other seventeen lots described in the "promise to sell" and the contract of lease. The Court clarified that the "compromiso de venta" and the "escritura de arrendamiento" were part of a whole scheme involving all twenty-four lots, and the payment of the redemption price was a condition precedent to Camara's undertaking to convey all twenty-four lots. Therefore, the issue of Camara's obligation to reconvey all 24 lots had already been definitively settled by this Court.
Main Doctrine
A complaint for reconveyance of certain lots, which could have been included in a previous action involving the same parties and based on the same contract, is barred by the rule against splitting of causes of action and by the principle of res judicata.