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HEIRS OF PURISIMA NALA v. ARTEMIO CABANSAG

FACTS:

Respondent Artemio Cabansag filed a case for damages against Purisima Nala and Atty. Alexander del Prado in October 1991. Respondent claimed that he bought a 50-square meter property from spouses Eugenio Gomez, Jr. and Felisa Duyan Gomez and received demand letters from Atty. Del Prado on behalf of Nala, asking for payment of rentals and threatening legal action. Atty. Del Prado asserted that he sent the demand letters in good faith, while Nala disputed respondent's claim of ownership, alleging that the property was part of her late husband's estate and that respondent was merely renting it.

The Regional Trial Court (RTC) ruled in favor of respondent and ordered Nala and Atty. Del Prado to pay damages. Nala and Atty. Del Prado, however, appealed the RTC decision to the Court of Appeals (CA). The CA affirmed the RTC decision with modification, taking into consideration another RTC branch's dismissal of Nala's case for reconveyance against the spouses Gomez.

In response, the heirs of Nala filed a petition for review, arguing that Nala had the right to assert her interests over the property.

ISSUES:

  1. Whether the Court of Appeals erred in not considering the right of Purisima Nala to assert her rights and interest over the property.

  2. Whether the Court of Appeals erred in not considering the Decision rendered by the Court of Appeals in the case for reconveyance which upheld the rights and interest of Purisima Nala and her children over a certain parcel of land, a portion of which is subject of the present case.

  3. Whether the Court of Appeals erred in awarding damages and attorney's fees without any basis.

RULING:

  1. The Court of Appeals did not err in not considering the right of Purisima Nala to assert her rights and interest over the property. The court upheld the RTC Decision in favor of respondent, finding that he is the rightful owner of the property and that Nala and Atty. Del Prado were liable for damages. There is no violation of Nala's right to assert her interests as the court has already made its ruling.

  2. The Court of Appeals did not err in not considering the Decision rendered by the Court of Appeals in the case for reconveyance. The present case is a separate civil case for damages filed by respondent against Nala and Atty. Del Prado. The ruling in the reconveyance case does not automatically affect the present case for damages.

  3. The Court of Appeals did not err in awarding damages and attorney's fees. The court found Nala and Atty. Del Prado liable for damages based on the evidence presented and the legal principles applied.

PRINCIPLES:

  • The court will uphold the ruling of the trial court if it finds that it was based on preponderance of evidence.

  • The decision in one case does not automatically affect a separate case, even if they involve the same parties or properties.

  • The court may award damages and attorney's fees based on the evidence and applicable legal principles.