Samonte v. Domingo
REITERATIONFacts
The Antecedents: Demetria N. Domingo (Domingo) filed a complaint for unlawful detainer against Alvin F. Samonte (Samonte) before the Metropolitan Trial Court (MeTC), alleging that she purchased the subject residential property from Samonte via a Deed of Sale of Residential House executed on July 8, 2011. Despite demands, Samonte refused to vacate and had rented out portions of the property. Samonte denied the sale, claiming he signed a document he believed to be a mortgage to secure a loan, and that Domingo defrauded him. Procedural History: The MeTC dismissed Domingo's complaint for failure to prove a lease contract and a demand letter. On appeal, the Regional Trial Court (RTC) reversed the MeTC, holding that an unlawful detainer action is not limited to lessors and that the demand to vacate was sufficiently alleged. Samonte's motion for reconsideration was denied. During the pendency of Samonte's petition for review with the Court of Appeals (CA), the RTC, in a separate case (Civil Case No. 12-128721), declared the Deed of Sale null and void, finding the transaction to be an equitable mortgage. This ruling was affirmed by the CA and became final and executory. The CA, in the unlawful detainer case, affirmed the RTC's decision, stating that the determination of ownership was provisional for possession purposes. Samonte moved for reconsideration, citing the supervening event of the deed's nullity. The CA denied the motion. The Petition: Samonte filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision and resolution in the unlawful detainer case.
Issue(s)
Whether Domingo has the right to possess the subject property, considering that the Deed of Sale she relied upon was declared null and void in a separate, final and executory case. Whether the principle of res judicata applies to bar Domingo's claim for possession based on a void deed of sale.
Ruling
The petition is GRANTED. The Decision dated August 17, 2017 and the Resolution dated February 13, 2018 in CA-G.R. SP No. 144022 are REVERSED and SET ASIDE. The Complaint for Unlawful Detainer is DISMISSED.
Ratio Decidendi
On the issue of Domingo's right to possess the subject property: The Court held that Domingo could no longer claim any right to possess the subject property based on the Deed of Sale of Residential House because this deed was declared null and void in a separate case (Civil Case No. 12-128721), which decision had attained finality on September 15, 2017. The Court emphasized that while ejectment cases generally do not abate suits for annulment of title, the final and executory judgment declaring the deed void is conclusive between the parties. Therefore, Domingo's claim of possession, anchored solely on this void instrument, must fail. The Court reiterated that in an unlawful detainer case, the sole issue is physical possession, and while ownership may be passed upon provisionally, any ruling on ownership does not bar actions regarding title. However, in this instance, the very basis of Domingo's claimed right to possession, the deed of sale, was definitively declared void. On the applicability of res judicata: The Court found that res judicata, specifically in the concept of conclusiveness of judgment, applies. It is undisputed that both the unlawful detainer case and the annulment of sale case involved the same parties and the same subject matter. Although the causes of action differed (possession versus validity of the deed), the issue of the deed's validity was directly adjudged in the annulment case and became final and executory. Conclusiveness of judgment precludes the relitigation of a particular fact or issue necessary to the outcome of a prior action between the same parties on a different claim. Since the Deed of Sale was declared null and void, this fact, having been judicially determined and finalized, cannot be relitigated in the unlawful detainer case to support Domingo's claim of possession. The Court cited Section 47(b) and (c) of Rule 39 of the Rules of Court in explaining the concept of res judicata.
Main Doctrine
Where a deed of sale, upon which a claim for possession in an unlawful detainer case is anchored, has been declared null and void in a separate case that has attained finality, the principle of res judicata, specifically conclusiveness of judgment, bars the relitigation of the validity of the deed, thereby negating any right to possession based on such void instrument.