Mandac v. Sales
REITERATIONFacts
The Antecedents: Petitioner Simeon Mandac filed an action for recovery of a parcel of land against respondents Victorino and Quirino Sales and Marcelo Garvida. The trial court declared Mandac the owner and ordered the Sales brothers to return possession and pay for products taken. The case was dismissed against Garvida. Procedural History: The Court of Appeals reversed the trial court's decision, absolving all defendants. The appellate court found that Teodoro Ramiscal, from whom Mandac claimed to have purchased the land, was merely a tenant of Ambrosio Segucio, who allegedly conveyed the land to Victorino Sales. The Petition: Petitioner contends that the Court of Appeals' finding disregards this Court's conclusion in a prior case (G.R. No. 38833) which held the possession of Teodoro Ramiscal's children as under a claim of ownership. Petitioner argues that this prior judgment should bind the present case.
Issue(s)
Whether the Court of Appeals erred in disregarding the Supreme Court's conclusion in G.R. No. 38833 regarding the nature of possession of the children of Teodoro Ramiscal. Whether the rule of conclusiveness of judgment applies to the present case concerning the disputed parcel of land and the respondents.
Ruling
The petition is denied. The judgment of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of disregarding the Supreme Court's conclusion in G.R. No. 38833: The Court held that the parcel of land in question was not disputed in the prior case G.R. No. 38833, even though it was part of the ten parcels conveyed by the children of Teodoro Ramiscal to Simeon Mandac. Furthermore, the respondents Victorino Sales and Quirino Sales were not parties to the said civil case. Therefore, the judgment of the Supreme Court in G.R. No. 38833 is not binding upon the parcel here in question nor upon the respondents Victorino and Quirino Sales. The Court of Appeals was thus free to make its own findings of fact regarding the ownership and possession of the land. On the applicability of the rule of conclusiveness of judgment: The Court clarified that the rule of conclusiveness of judgment, as embodied in section 307 of Act No. 190 (now Rule 139, sec. 45, Rules of Court), does not apply in this instance. This is because the specific parcel of land in dispute was not the subject of the previous litigation, and the present respondents were not parties to that prior case. Consequently, the principle of res judicata or conclusiveness of judgment cannot be invoked to bind the parties or the subject matter in the current action. The Court of Appeals, therefore, was not precluded from conducting its own inquiry and making its own determination based on the evidence presented before it.
Main Doctrine
The rule of conclusiveness of judgment does not apply when the subject parcel of land was not disputed in the prior case, nor were the present respondents parties to that case.