Garcia v. Fenoy
REITERATIONFacts
The Antecedents: Plaintiffs Vicente Garcia, Benjamin Garcia, and Anatalia Garcia were plaintiffs in Civil Case No. 13847, where a notice of lis pendens was filed concerning Original Certificate of Title No. 25381. Pedro de Guzman, the defendant in that case, had obtained a judgment for P55,754.26 plus interest in Civil Case No. 8425 for a portion of the land involved in Case No. 13847, which was expropriated by the Government for the Agno River Control Project. Defendant Jose Fenoy was counsel for De Guzman in Case No. 8425. Fenoy allegedly urged plaintiff Meris-Morales (counsel for plaintiffs in Case No. 13847) to sign a communication to the Register of Deeds stating that the lis pendens only covered the remaining portion of the land not taken by the Government. Fenoy allegedly promised Meris-Morales and his clients one-fourth (1/4) of the amount to be collected from the Government as compensation for the expropriated property. Meris-Morales, with his clients' consent, signed the communication. De Guzman collected the P55,754.26. When plaintiffs demanded compliance with the promise, Fenoy stated his client De Guzman was not agreeable until the final determination of Case No. 13847. Plaintiffs alleged Fenoy was personally bound due to deceit and fraud, causing them damages, and prayed for one-fourth of the collected sum, plus attorney's fees. Procedural History: Defendant Fenoy filed a motion for production of the actionable document and suspension of the period to answer. Plaintiffs submitted a statement of the document, which read: "Segunda el resultado del asunto en la Corte Suprema, dare una cuarta (1/4) parte del dinero que se saque del dique, al abogado Meris para el y su clientes." Fenoy alleged that the phrase "segunda el resultado del asunto en la Corte Supreme" was crossed out without his initials or signature, and that this deletion did not exist when he signed. Fenoy moved to dismiss the complaint for stating no cause of action and for the cause of action not having accrued. The lower court granted the motion, reasoning that Fenoy lacked authority from his client to make such a promise and that plaintiffs had no cause of action until a final decision in Case No. 13847 (then pending appeal in the Supreme Court as G.R. No. L-15988) favored them. Plaintiffs appealed. The Petition: Plaintiffs-appellants argued that the lower court erred in not holding that defendant-appellee is estopped from denying his authority to make the promise. The Supreme Court noted that in Civil Case No. 13847, plaintiffs sought to cancel De Guzman's title to the land, claiming it was fraudulently secured. De Guzman had moved to dismiss that case based on a prior judgment and the statute of limitations. The Supreme Court, in G.R. No. L-15988, affirmed the dismissal, finding that the property was claimed by plaintiffs as heirs of the original owner, Juan Garcia, who had donated it to De Guzman in 1918. De Guzman obtained a registration judgment in 1923, and OCT No. 25381 was issued. The Supreme Court held that plaintiffs' claim was barred by the decree of registration and the statute of limitations, as their complaint was filed in 1959.
Issue(s)
Whether the plaintiffs have a valid cause of action to enforce the written promise made by the defendant attorney.
Ruling
The order appealed from is hereby affirmed, with costs against plaintiffs-appellants.
Ratio Decidendi
On Issue 1: The Court held that the plaintiffs had no cause of action against the defendant. The existence of a cause of action depends on whether the plaintiffs suffered a legal injury through the violation of a subsisting right. In the related case of Garcia v. De Guzman (G.R. No. L-15988), the Supreme Court definitively ruled that the plaintiffs' claim to the land was barred because the property had been registered in De Guzman's name since 1923, and the action to cancel the title was filed only in 1959. This lapse of time meant the claim was barred by both the decree of registration and the statute of limitations. Therefore, the plaintiffs had no actual right to the land involved in Civil Cases Nos. 8425 and 13847. Since they had no right to the land, the partial cancellation of the notice of lis pendens caused them no damage whatsoever. Without damage or a violated right, there can be no cause of action, regardless of the written promise made by the defendant attorney or the circumstances of its execution.
Main Doctrine
A party who has suffered no damage or injury cannot maintain an action for deceit or fraud, as the absence of damage negates the existence of a cause of action.