Gonzales v. Gonzales
REITERATIONFacts
The Antecedents: Plaintiff Geminiano L. Gonzales filed a complaint against Saturnina Gonzales and several others, alleging co-ownership with the defendants over specific cadastral lots (Lot No. 570, northern portion of Lot No. 566, and Lot No. 572) based on a decision dated August 27, 1960, in Civil Case No. 806, which was affirmed by the Court of Appeals on October 9, 1962. The plaintiff claimed that the defendants were in possession of 3.5381 hectares belonging to him, which should have yielded 20 cavans of palay per agricultural year from 1952 to 1963, resulting in damages of P2,642.00. He also claimed that the defendants possessed the entire 7.0762 hectares, including a sugar quota of 206 from Central Azucarera de Tarlac, of which 103 pertained to him, causing him damages of P7,931.00 for the use of the quota from 1952 to 1963. The plaintiff further alleged that the defendants refused to pay these amounts and to partition and reconvey his share of the land, produce, and sugar quota, causing him moral and liquidated damages, and attorney's fees. Procedural History: The defendants moved to dismiss the case on the grounds of res judicata and prescription. The Court of First Instance granted the motion, ruling that the plaintiff's claims for possession and fruits should have been raised in Civil Case No. 806. The plaintiff appealed this dismissal. The Petition: The plaintiff-appellant contended that the decision in Civil Case No. 806, which was for reconveyance of title or recovery of ownership, did not constitute res judicata to the present action for recovery of possession and fruits.
Issue(s)
Whether the decision in Civil Case No. 806 constitutes res judicata to the present action for recovery of possession and fruits. Whether the claim for fruits and sugar quota could have been litigated in the prior case.
Ruling
The Supreme Court affirmed the order of dismissal. It held that the decision in Civil Case No. 806, which declared the plaintiff and defendants as co-owners and ordered partition and reconveyance, also implicitly adjudicated the right to possession. The Court found that the plaintiff's claims for possession and fruits should have been raised in the prior case, as they were matters that could have been litigated therein. The sugar quota was considered an improvement attached to the land, thus also covered by the prior judgment.
Ratio Decidendi
On the issue of res judicata: The Court held that the decision in Civil Case No. 806, which declared the plaintiff and defendants as co-owners of the lots and ordered partition and reconveyance, also implicitly adjudicated the right to possession. The dispositive portion of the prior decision explicitly ordered the defendants to vacate the specific portions assigned to the plaintiff after partition. Therefore, the claim for possession was already covered by the prior judgment and did not necessitate a separate action. The Court reiterated the principle that a former judgment bars subsequent actions not only on matters expressly adjudged but also on all matters that could have been brought and determined in the first case. The recognition of the right to possession logically follows from the judicial declaration of ownership. On the issue of claims for fruits and sugar quota: The Court ruled that the claim for fruits accruing to the plaintiff's share of the property during the period he was deprived of possession should have been pleaded in Civil Case No. 806. Since the plaintiff failed to raise this issue in the prior case, he could not ventilate it in the present proceeding. The rule is well-settled that a former judgment bars the presentation in another action of all matters that could have been adjudged in the first case. Similarly, the sugar quota, being an improvement attached to the land, was also covered by the prior judgment and should have been claimed therein.
Main Doctrine
A former judgment bars a subsequent action not only as to matters expressly adjudged but also as to all matters that could have been brought and determined in the former case, including claims for possession and fruits of property, if these could have been pleaded therein.