Del Rosario v. Jacinto
REITERATIONFacts
The Antecedents: Pilar, Mariano, and Salvador del Rosario filed an action for reconveyance and/or recovery of a 2,879 square-meter parcel of land in Quezon City, covered by Transfer Certificates of Title Nos. 26531 and 26532, against Sancho R. Jacinto, Domingo C. Bascara, and J.M. Tuason & Co., Inc. This case was docketed as Civil Case No. 5230 in the Court of First Instance (CFI) of Rizal, Pasig Branch. Procedural History: Subsequently, Pilar, Mariano, and Salvador del Rosario, along with Aniana Deudor, Macaria Fulgencio, and Carlos Javier, filed another action for the same relief concerning the same parcel of land against the same defendants. This second action was docketed as Civil Case No. 2254-P in the CFI of Rizal, Pasay City Branch. The plaintiffs in the Pasay case moved to transfer it to the Pasig Branch where Civil Case No. 5230 was pending. However, the court ordered the transfer of Case No. 2254-P to the CFI of Rizal, Quezon City Branch, citing the location of the land. It was then docketed as Civil Case No. Q-6324. The Appeal: Defendants in Case No. Q-6324 moved to dismiss the complaint on the ground of lis pendens, citing the pendency of Case No. 5230. The court granted the motion and dismissed Case No. Q-6324. Plaintiffs moved for reconsideration, seeking to amend their complaint to include only Aniana Deudor, Macaria Fulgencio, and Carlos Javier as plaintiffs, and Sancho R. Jacinto and Domingo C. Bascara as defendants. The court denied the motion for reconsideration and the admission of the amended complaint. Plaintiffs appealed directly to the Supreme Court.
Issue(s)
Whether the second suit (Civil Case No. Q-6324) is barred by lis pendens.
Ruling
The Supreme Court affirmed the order of dismissal of the Court of First Instance. The Court found that all the requisites for lis pendens were attendant in the case, thus the second action was correctly dismissed.
Ratio Decidendi
On Issue 1: The Court held that the second suit, Civil Case No. Q-6324, was indeed barred by lis pendens. The Court meticulously examined the three requisites for lis pendens. Firstly, regarding the identity of parties, the Court noted that the plaintiffs in the second case (Deudor, Fulgencio, Javier) were the original owners from whom the plaintiffs in the first case (Pilar, Mariano, Salvador del Rosario) allegedly bought the land, thus representing the same interests. The elimination of J.M. Tuason & Co., Inc. as a defendant did not alter the situation, as the remaining defendants were sued as purchasers from J.M. Tuason & Co., Inc. and thus represented the same interests. Secondly, the Court found an identity of rights asserted and relief prayed for, as both cases sought reconveyance and/or recovery of the same parcel of land. The basis for these claims in both actions was the compromise agreement executed on March 16, 1953. Thirdly, the Court concluded that any judgment rendered in the first case (Civil Case No. 5230) would constitute res judicata in the second case (Civil Case No. Q-6324), as parties basing their claims on the same rights are bound by the judgment in a prior suit. Therefore, all requisites for lis pendens were met, justifying the dismissal of the second case.
Main Doctrine
The Court reiterated that the existence of lis pendens as a ground to dismiss a complaint requires the presence of three requisites: (1) identity of parties, or at least such as represent the same interests in both actions; (2) identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (3) identity in both cases is such that the judgment that may be rendered in the pending case would, regardless of which party is successful, amount to res judicata in the other. The Court found these requisites present, affirming the dismissal of the second case.