Frances v. Nicolas
REITERATIONFacts
The Antecedents: Sergio Nicolas applied for a homestead in 1917. He died survived by his widow, Nieves Tinio (Mrs. Nicolas), and six children. Plaintiffs, Mr. & Mrs. Frances, alleged that they purchased portions of the lot from the heirs of Nicolas between 1945 and 1948, paying an aggregate sum of P13,700.00 for their rights. Subsequently, Mrs. Nicolas and her children filed Civil Case No. 1180 to annul the transfer of rights and recover the lot, alleging fraud. The Court of First Instance ruled in favor of the plaintiffs, which was appealed to the Supreme Court (G.R. No. L-7747). Procedural History: In G.R. No. L-7747, the Supreme Court nullified the conveyances and ordered the return of the lot to the heirs of Nicolas upon refund of the price paid by the plaintiffs. When the records were remanded, the heirs of Nicolas, except Carlos, allegedly misrepresented the price paid by the plaintiffs as P2,500.00, not P13,700.00. Consequently, the lower court ordered the plaintiffs to turn over possession upon refund of P2,500.00. The plaintiffs filed a petition for certiorari (G.R. No. L-11249) to annul these orders, alleging grave abuse of discretion. This petition was dismissed by the Supreme Court for lack of merit. The present complaint was filed by the plaintiffs seeking damages, alleging that the heirs of Nicolas fraudulently misrepresented the price paid. The Petition: The defendants moved to dismiss the complaint, arguing it was barred by the decision in G.R. No. L-7747 and the resolution in G.R. No. L-11249. The lower court granted the motion and dismissed the complaint. Plaintiffs appealed.
Issue(s)
Whether the present complaint is barred by the decision in G.R. No. L-7747 and the resolution in G.R. No. L-11249. Whether the orders dated August 2, 1956, and August 23, 1956, which fixed the refundable amount, have become final and executory.
Ruling
The Supreme Court affirmed the order of the lower court dismissing the complaint, with costs against the plaintiffs-appellants.
Ratio Decidendi
On the issue of whether the present complaint is barred by prior decisions: The Court held that the issue regarding the sum collectible by the plaintiffs had already been settled by the orders dated August 2, 1956, and August 23, 1956, which had become final and executory. These orders were issued pursuant to the Supreme Court's decision in G.R. No. L-7747, which directed the refund of the price paid by the plaintiffs. The subsequent petition for certiorari in G.R. No. L-11249, seeking to annul these orders, was dismissed by the Supreme Court for lack of merit. Therefore, the matter could no longer be reopened in the present proceedings, as it was already covered by the principle of res judicata. The Court cited Soriano vs. Sahagun (L-17847, March 31, 1964) in support of this principle, emphasizing that the present action was instituted over four years after the issuance of the said orders and the dismissal of the certiorari petition. On the finality and executory nature of the orders: The Court reiterated that the orders of August 2 and 23, 1956, particularly the order of August 2, 1956, which fixed the amount recoverable by the plaintiffs, partook of the nature of a decision or judgment. Since no appeal was taken from these orders and the petition for certiorari to annul them was dismissed, they had attained finality and executory status. Consequently, the issue concerning the sum collectible by the plaintiffs, as determined by the Supreme Court in G.R. No. L-7747, was definitively settled by these orders and could not be relitigated. The plaintiffs' attempt to reopen this issue through a new complaint was thus barred by prior judgment.
Main Doctrine
A matter that has become final and executory, having been passed upon by the Supreme Court in a previous decision and a subsequent resolution dismissing a petition for certiorari, cannot be reopened in subsequent proceedings.