Custodio v. Corrado
REITERATIONFacts
The Antecedents: Respondent Rosendo F. Corrado filed a complaint for recovery of possession and ownership with injunction and damages against petitioner Melchor Custodio, alleging that he is the registered owner of a residential lot and that petitioner, without his knowledge and consent, demolished his old house and constructed a bungalow thereon. Procedural History: The Municipal Trial Court (MTC) initially dismissed respondent's ejectment case (Civil Case No. 116) for lack of jurisdiction, absence of barangay conciliation, and failure to prove his case. Subsequently, respondent filed another complaint (Civil Case No. 120) for recovery of possession and ownership. The MTC dismissed this second complaint, finding that petitioner had a legal basis for his stay due to a tenancy relationship with respondent's father and that the prior ejectment case was not decided on the merits. Upon appeal, the Regional Trial Court (RTC) reversed the MTC decision, declaring respondent as the owner and ordering petitioner to vacate. The Court of Appeals (CA) affirmed the RTC decision. The Petition: Petitioner sought review of the CA's decision, raising issues on the applicability of res judicata, the identity of causes of action, and the establishment of a tenancy relationship.
Issue(s)
Whether the Court of Appeals erred in holding that Civil Case No. 116 and Civil Case No. 120 have two separate causes of action despite the material allegations in the complaints, and whether res judicata applies considering the nature of the prior judgment and the identity of causes of action. Whether the petitioner amply established by preponderance of evidence a tenancy relationship with respondent and his father, Crisanto Corrado. What is the distinction between ejectment, accion publiciana, and accion reinvindicatoria?
Ruling
The Supreme Court denied the petition for lack of merit and affirmed the decision of the Court of Appeals. The Court held that the principle of res judicata is inapplicable because the prior ejectment case (Civil Case No. 116) was not decided on the merits and its cause of action is different from the present case for recovery of possession and ownership (Civil Case No. 120). Furthermore, the Court found no compelling reason to set aside the CA's findings regarding the lack of established tenancy relationship, especially in light of the stipulation of facts during pre-trial.
Ratio Decidendi
On the applicability of res judicata and the causes of action: The Court reiterated that for res judicata to apply, five requisites must concur: (1) the former judgment must be final; (2) it must be rendered by a court having jurisdiction; (3) it must be a judgment on the merits; (4) there must be identity of parties; (5) identity of subject matter; and (6) identity of cause of action. In this case, the judgment in Civil Case No. 116 was not on the merits, as it was dismissed on technical points such as lack of jurisdiction and failure to prove the date of demand, without determining the rights of the parties. A judgment dismissing an action for want of jurisdiction cannot operate as res judicata on the merits. Furthermore, there is no identity of causes of action between Civil Case No. 116, an ejectment suit, and Civil Case No. 120, a case for recovery of possession and ownership. An ejectment case only disposes of the issue of possession, while an accion publiciana or accion reinvindicatoria determines the right of possession as an element of ownership or ownership itself. The Court clarified that Civil Case No. 120 is more of an accion reinvindicatoria, given the allegation of registered ownership. On the alleged tenancy relationship: The Court held that the issue of tenancy relationship is a factual issue that is generally not proper for a petition for review on certiorari. Moreover, this issue had already been squarely resolved by the Court of Appeals, which found that the milling tickets presented did not sufficiently establish the tenancy relationship concerning the subject lot. Crucially, the parties had stipulated during the pre-trial conference that the subject lot is registered in the name of respondent and that petitioner was never a tenant of respondent. These stipulations are binding on the parties and need not be proven during trial, as pre-trial aims to simplify and expedite the resolution of cases by clarifying and limiting the issues. On the distinction between ejectment, accion publiciana, and accion reinvindicatoria: The Court emphasized the well-settled distinction between a summary action of ejectment and a plenary action for recovery of possession and/or ownership. An ejectment suit (accion interdictal) is limited to the question of de facto possession. Accion publiciana is a plenary action to recover the right of possession, while accion reinvindicatoria is an action to recover ownership which includes recovery of possession. The judgment in an ejectment case does not bar an action for the determination of title or ownership.
Main Doctrine
The principle of res judicata is inapplicable when the former judgment was not on the merits, or when there is no identity of causes of action between the two cases, such as when one is an ejectment suit and the other is for recovery of possession and ownership.