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EMILIANO S. SAMSON v. SPS. JOSE

FACTS:

Respondent spouses, Jose and Guillermina Gabor, owned a parcel of land in Tanay, Rizal. In 1985, they transferred a portion of the land to petitioner Samson as attorney's fees. In 1987, Samson transferred the same portion to Ma. Remedios Ramos. The Gabor spouses filed an action for legal redemption, which was granted by the Court of Appeals (CA). During that time, Samson filed an action for partition of the property, which was dismissed by the RTC. The dismissal was upheld by the CA, stating that the finality of the legal redemption case barred the action for partition. In 2006, Samson filed a complaint for recovery of property or its value, claiming that he had been paying realty taxes for the subject portion. The RTC dismissed the complaint on the grounds of improper venue, res judicata, and lack of cause of action. The dismissal was affirmed by the CA.

The petitioner appealed the dismissal of his complaint to the Court of Appeals (CA), arguing that the CA had jurisdiction over the appeal. The CA dismissed the appeal as it raised only issues of law, involving the application of the law and not the review of facts. The Regional Trial Court (RTC) of Pasig City had dismissed the petitioner's complaint on the ground that it should have been filed in the RTC of Morong, Rizal, where the property subject of the case is situated. Petitioner claimed that his cause of action is in the alternative, both real and personal. The RTC of Pasig City also dismissed the complaint for failing to state a cause of action as it did not provide any details of the defendant's liabilities or violations of the plaintiff's rights.

The petitioner filed a complaint against the respondent bank, alleging a violation of his rights. However, the petitioner failed to specify the details of his cause of action against the respondent bank and did not state specific overt acts by the bank in disregard of the petitioner's rights. The court stressed the importance of a clear statement of cause of action in a complaint and the need for specific allegations.

ISSUES:

  1. Whether the plaintiff sufficiently stated a cause of action against the defendant bank in the complaint.

  2. Whether the current action for recovery of property or its value is barred by res judicata.

  3. Whether the doctrine of res judicata applies in this case.

  4. Whether the dismissal of the petitioner's earlier complaint for Partition of Real Property and Damages constitutes res judicata.

  5. Whether there is identity of causes of action between the prior action for partition and the subsequent action for recovery of property.

  6. Whether the change in the title of the action from "Complaint for Partition of Real Property and Damages" to "Complaint for Recovery of Property or its Value" affects the identity of causes of action.

  7. Whether or not the complaint should be dismissed on the grounds of improper venue, res judicata, and lack of cause of action.

  8. Whether or not the petitioner's appeal should be dismissed for raising only issues purely of law.

RULING:

  1. The plaintiff failed to sufficiently state a cause of action against the defendant bank in the complaint. The complaint lacked specific overt acts to show that the defendant bank acted in disregard of the plaintiff's rights. The plaintiff should have specified the details of his cause of action against the defendant bank.

  2. The current action for recovery of property or its value is barred by res judicata. To bar a subsequent action, the following requisites must concur: (1) the judgment sought to bar the new action must be final; (2) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be identity of parties, subject matter, and causes of action between the first and second action.

  3. Yes, the doctrine of res judicata applies in this case.

  4. Yes, the dismissal of the petitioner's earlier complaint for Partition of Real Property and Damages constitutes res judicata.

  5. Yes, there is identity of causes of action between the prior action for partition and the subsequent action for recovery of property. The test used in determining whether causes of action are identical is whether the same evidence necessary to sustain the second action would have been sufficient to authorize a recovery in the first. In this case, the evidence submitted by the parties in both cases are identical, and both cases involve the claim of ownership over the subject property. The ultimate question in both cases was whether the petitioner is a co-owner of the subject property. Therefore, there is identity of causes of action.

  6. No, the change in the title of the action does not affect the identity of causes of action. The change in title from "Complaint for Partition of Real Property and Damages" to "Complaint for Recovery of Property or its Value" does not change the fact that the issues raised essentially involve the claim of ownership over the subject property. Even if the forms or nature of actions in both cases are different, there is still identity of causes of action because the same evidence would sustain both actions.

  7. The Regional Trial Court of Pasig City correctly dismissed the complaint on the grounds of improper venue, res judicata, and lack of cause of action.

  8. The Court of Appeals likewise correctly dismissed the petitioner's appeal for raising only issues purely of law.

PRINCIPLES:

  • A cause of action arises when the following elements are present: (a) a right in favor of the plaintiff by whatever means and under whatever law it arises or is created; (b) an obligation on the part of the named defendant to respect or not to violate that right; and (c) an act or omission on the part of such defendant violative of the right of the plaintiff or constituting a breach of the obligation of the defendant to the plaintiff for which the latter may maintain an action for recovery of damages or other appropriate relief.

  • In determining whether an initiatory pleading states a cause of action, the test is whether the court can render a valid judgment in accordance with the prayer based on the alleged facts, admitting their truth.

  • Extraneous facts, circumstances or other matters aliunde are not considered in determining the existence of a cause of action. Only the material allegations in the complaint are taken into account.

  • Res judicata bars the institution of a subsequent action when the following requisites concur: (a) the judgment sought to bar the new action must be final; (b) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (c) the disposition of the case must be a judgment on the merits; and (d) there must be identity of parties, subject matter, and causes of action between the first and second action. The principle of res judicata prevents parties from litigating the same issue more than once.

  • Res judicata means "a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment."

  • Res judicata is a rule that pervades every well-regulated system of jurisprudence and is founded upon two grounds: (1) public policy and necessity, and (2) the hardship on the individual.

  • Res judicata has two concepts: bar by prior judgment and conclusiveness of judgment.

  • Bar by prior judgment exists when there is identity of parties, subject matter, and cause of action in the first and second actions.

  • Conclusiveness of judgment exists when there is identity of parties and subject matter, but the causes of action are completely distinct.

  • The judgment in the first action is final as to the claim or demand in controversy, including the parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose and of all matters that could have been adjudged in that case.

  • A cause of action is defined as the act or omission by which a party violates a right of another.

  • A party may not institute more than one suit for a single cause of action.

  • If two or more suits are instituted on the basis of the same cause of action, the filing of one or a judgment upon the merits in any one is available as a ground for the dismissal of the others.

  • The test for identity of causes of action is whether the same evidence necessary to sustain the second action would have been sufficient to authorize a recovery in the first, even if the forms or nature of the two actions are different.

  • The issue of ownership or co-ownership must be resolved before a court may issue an order of partition. An action for partition will not lie if the claimant has no rightful interest over the subject property.

  • Once a judgment has become final, the winning party should not be deprived of the fruits of the verdict.

  • Exceptions to the immutability of final judgment are allowed only under extraordinary circumstances.

  • When a party is given ample opportunity to be heard and has unbridled access to the appellate courts, the findings of the courts below should not be recklessly reversed.