Velasco v. Velasco
REITERATIONFacts
The Antecedents: Plaintiffs Maria Velasco and Maria Aborde, claiming to be co-owners of certain properties (Parcels I, II, and III) left by the intestate estate of Exequiel Velasco, filed a complaint against defendant Carlos Velasco. Carlos Velasco had taken possession of Parcels I and II in 1929, claiming ownership. Parcel III was the subject of a previous litigation (Civil Case No. 833, confirmed by the Court of Appeals in CA-G.R. No. 8085-R) between Maria Aborde and her husband as plaintiffs and Carlos Velasco as defendant, where the latter prevailed due to the presentation of certain documents (Annexes A, B, and C). The plaintiffs in the present case sought to have Parcels I and II declared as owned in common, Parcel III as exclusively owned by Maria Aborde, to have Carlos Velasco vacate Parcels I and II, and to declare Annexes A, B, and C null and void for being false and forged. They also sought to annul the previous Court of Appeals decision in CA-G.R. No. 8085-R, alleging it was obtained through fraudulent means by presenting falsified documents, and to prevent its execution. Additionally, they prayed for damages and attorney's fees. Procedural History: Defendant Carlos Velasco filed a motion to dismiss, arguing that the causes of action were barred by a prior judgment and had prescribed. The lower court initially denied the motion to dismiss, finding no identity of parties and subject matter for the first ground, and that prescription could not be alleged as the complaint did not aver open, public possession under a claim of title since 1929. However, on reconsideration, the lower court sustained the motion to dismiss as to Maria Aborde concerning Parcel III. Plaintiffs appealed this order, and the case was certified to the Supreme Court as the issue was legal. The Petition: The Supreme Court was asked to determine if the former judgment in Civil Case No. 833 operated as a bar to the present case, specifically concerning Parcel III, under the principle of res judicata.
Issue(s)
Whether the former judgment in Civil Case No. 833 (CA-G.R. No. 8085-R) is a bar to the present case concerning Parcel III under the principle of res judicata. Whether the judgment in Civil Case No. 833 can be annulled on the ground of alleged fraud in the presentation of forged documents.
Ruling
The Supreme Court affirmed the order of the lower court dismissing the complaint of Maria Aborde with respect to Parcel III. The Court held that the former judgment in Civil Case No. 833 was conclusive on the matter of Parcel III between Maria Aborde and Carlos Velasco, and that the alleged fraud in presenting forged documents was intrinsic and did not warrant annulment of the judgment.
Ratio Decidendi
On the issue of res judicata concerning Parcel III: The Court held that the former judgment in Civil Case No. 833 was a bar to the present case concerning Parcel III. Although Maria Velasco was an additional plaintiff in the present case, she was considered in privity with Maria Aborde, who was a party in the former case. Both plaintiffs alleged co-ownership and had a community of interest. The subject matter (Parcel III) and the cause of action (declaration of ownership and recovery of possession) were the same in both cases. The Court cited established jurisprudence that res judicata applies even if new parties are joined in the second action, provided the party against whom the judgment is offered was a party in the first action. The principle of res judicata applies not only to matters actually determined but also to those that might have been litigated and decided incident to or essentially connected with the subject matter of the litigation. The same evidence would support both the present and former causes of action, making the probability of forgery irrelevant to the application of res judicata. On the issue of annulment of judgment: The Court ruled that the judgment in Civil Case No. 833 could no longer be annulled. The alleged fraud, which consisted of the admission of supposedly false or forged documents, was intrinsic in character. The Court distinguished intrinsic fraud from extrinsic fraud, stating that only extrinsic fraud would warrant a court to set aside or annul a judgment. Intrinsic fraud pertains to issues decided within the case itself, such as the authenticity of evidence, while extrinsic fraud relates to matters outside the issues of the case that prevented a fair submission of the controversy. The presentation of forged documents, as alleged by the plaintiffs, falls under intrinsic fraud, which cannot be a basis for annulling a final and executory judgment.
Main Doctrine
A prior judgment is conclusive on the rights of the parties or their privies in all other actions or suits between them on the points and matters in issue in the first suit, and an annulment of judgment based on intrinsic fraud, such as the presentation of forged documents, is generally not allowed.