GR L 17476; (November,1961) (Digest)
G.R. No. L-17476. November 30, 1961. BERNARDO CORDA, ET AL., plaintiffs-appellants, vs. EUGENIO MAGLINTI, defendant-appellee.
FACTS
The plaintiffs-appellants, Bernardo Corda et al., initially filed an action in 1948 to recover two parcels of land and damages for fruits received by the defendant-appellee, Eugenio Maglinti, from 1939. The trial court dismissed the complaint. On appeal, the Court of Appeals modified the decision, declaring plaintiffs as owners of 5/7 of the property and defendant as owner of 2/7, while affirming the dismissal in all other respects, which implicitly included the claim for damages. This decision became final. Subsequently, plaintiffs filed a separate action for partition. The parties submitted a written stipulation of settlement for the physical division of the lots, which included a clause reserving “whatever claims the parties have against each other” for court determination. The trial court approved the stipulation.
After the properties were partitioned and delivered, plaintiffs sought to present evidence on their claim for damages for the unlawful deprivation of fruits from their share during the period of dispossession, invoking the reservation clause. The defendant objected on the ground of res judicata. The trial court denied plaintiffs’ request to present evidence and considered the case terminated.
ISSUE
Whether the plaintiffs’ claim for damages for the fruits of the property during their dispossession is barred by res judicata, notwithstanding the reservation clause in the partition stipulation.
RULING
Yes, the claim is barred by res judicata. The Supreme Court affirmed the trial court’s order. The legal logic is grounded on the finality of the prior judgment. In the original 1948 complaint, plaintiffs explicitly pleaded for recovery of the land and damages for the fruits unlawfully received by the defendant from 1939 to 1948. They presented evidence on both claims. The trial court dismissed the entire complaint. The Court of Appeals, while modifying the ownership declaration, affirmed the dismissal in all other respects. Notably, one of the assigned errors appellants raised before the Court of Appeals was the trial court’s failure to award damages, but the appellate court passed upon this matter sub silentio, leaving the dismissal of the damage claim intact. This decision became final and conclusive.
The principle of res judicata precludes the relitigation of the same cause of action between the same parties. The claim for damages for the period up to 1948 was integral to the first case, was fully litigated, and was definitively settled by the final judgment. The reservation clause in the subsequent partition stipulation cannot revive that already adjudicated claim. The Court clarified that the reservation likely pertained to other matters not previously litigated, such as issues arising from the receivership established in the first case, which should be resolved in that separate proceeding. Therefore, the trial court correctly barred the presentation of evidence on the barred damage claim.