GR L 8541; (July, 1917) (Digest)
G.R. No. and Date: G.R. No. L-8541; July 20, 1917
Case Title: APOLONIO DEATO and DIEGA FRANCISCO, plaintiffs-appellees, vs. CLARO ZACARIAS and CRISTINA LORENZO, defendants-appellants.
FACTS:
The plaintiffs, Apolonio Deato and Diega Francisco, filed an action in the Court of First Instance of Bulacan on January 31, 1911, to recover possession and ownership of a parcel of land, along with damages for its use and occupation. The defendants, Claro Zacarias and Cristina Lorenzo, were in possession of the land by virtue of a judgment in an earlier desahucio (ejectment) case decided by a justice of the peace. However, that judgment was reversed on appeal to the Court of First Instance. The trial court found that the plaintiffs were the owners of the land and ordered the defendants to deliver possession to them, but denied the claim for damages due to insufficient evidence. The defendants appealed, arguing that the prior judgment in the desahucio case was res judicata and barred the present action.
ISSUE:
Whether the judgment in the prior desahucio (ejectment) case constitutes res judicata in a subsequent action to recover ownership of the same land.
RULING:
No. The Supreme Court affirmed the decision of the lower court. The Court held that a judgment in an action of desahucio (where only the right to possession is at issue) is not res judicata in a subsequent action to recover ownership of the property. The Court explained that ownership and possession are distinct legal issues; a tenant may have the right to possession in an ejectment suit, but the landlord may still prove ownership in a separate action. Since the defendants admitted that the prior desahucio judgment was reversed on appeal, and because such judgments do not settle questions of title, the defense of res judicata was untenable. The Court cited precedents, including Ty Laco Cioco vs. Muro and Roman Catholic Church vs. Familiar, to support this doctrine. Accordingly, the judgment ordering the defendants to deliver possession to the plaintiffs was affirmed, with costs against the appellants.
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