GR L 1580; (November, 1949) (Digest)
G.R. No. L-1580; November 29, 1949
RAMON MARTINEZ as guardian of the incompetent Pedro Martinez, plaintiff-appellant, vs. JACINTO NOTOR, defendant-appellee.
FACTS
Ramon Martinez, as guardian of the incompetent Pedro Martinez, filed an action (Civil Case No. 3957) concerning a contract of lease over two parcels of land. These same parcels were previously the subject of a mortgage contract between the same parties, which was litigated in a prior case (Civil Case No. 181). In that prior case, the guardian had consigned payment to redeem the mortgage, and the Supreme Court, in G.R. No. L-1892, ultimately affirmed the validity of the redemption and declared the mortgage debt extinguished. In the present case, the defendant-appellee moved to dismiss on the ground of lis pendens (another action pending) and later, by implication, res judicata. The Court of First Instance of Batangas dismissed the complaint, ruling that the issue in the present case (termination of the lease) was inextricably linked to and would be resolved by the outcome of the prior mortgage redemption case.
ISSUE
Whether the present action is barred by the principle of res judicata, given the Supreme Court’s final decision in the prior mortgage redemption case (G.R. No. L-1892).
RULING
Yes. The Supreme Court affirmed the dismissal of the complaint. The Court held that the principle of res judicata applies. The parties, subject matter (the same two parcels of land), and cause of action in both cases are identical. The core issue in the present lease case—whether the lease contract was terminated—is necessarily dependent on the issue already conclusively settled in the prior mortgage case: the validity of the mortgage redemption. Since the Supreme Court had already ruled in G.R. No. L-1892 that the mortgage was validly redeemed and the debt extinguished, the lease, which was conditioned upon the subsistence of the mortgage debt, was likewise terminated. Therefore, the present action raised no new issue and was barred by the prior final judgment.
AI Generated by Armztrong.