G.R. No. L-26112. April 11, 1972.
REPUBLIC OF THE PHILIPPINES, ET AL. vs. HON. JAIME DE LOS ANGELES, ET AL.

FACTS

This case involves a dispute over Lot 360, a fishpond area within Hacienda Calatagan, Batangas, which was declared part of the public domain. Miguel Tolentino, Sr., a fishpond lease applicant, intervened in an earlier case (G.R. No. L-20950) and secured a judgment from the Court of First Instance (CFI) against the Dizons (actual possessors) and respondent Ayala y Cia. The CFI ordered the Dizons and Ayala to deliver possession to the Republic and awarded Tolentino compensatory damages of P3,000 per hectare annually from March 11, 1954, until he is placed in possession, payable by the defendants. On appeal, the Supreme Court modified this judgment. It declared the Dizons as possessors in good faith, entitled to retain the property and its fruits until reimbursed for necessary expenses, and absolved them from liability for damages. The decision was silent on Ayala’s liability for the damages awarded by the CFI.

ISSUE

The core issue is whether, following the Supreme Court’s final decision in G.R. No. L-20950, respondent Ayala y Cia. remains solidarily liable with the Dizons to pay the massive compensatory damages (estimated at nearly P2 million) awarded by the trial court to petitioner Miguel Tolentino, Sr.

RULING

No. The Supreme Court, through the concurring opinion of Justice Makalintal, denied Tolentino’s claim for damages against Ayala. The legal logic is anchored on the final and controlling effects of the Court’s decision in G.R. No. L-20950. That decision established that the Dizons, as possessors in good faith, have a right to retain possession and receive the fruits of the land until reimbursed for necessary expenses. Consequently, as long as the Dizons rightfully hold possession and are entitled to the fruits, Tolentino can have no concurrent right to either possession or those same fruits. The award of damages to Tolentino under Article 549 of the Civil Code was predicated on the Dizons being possessors in bad faith—a premise explicitly overturned by the Supreme Court. Since the basis for the damage award was extinguished by the higher court’s ruling, the liability for such damages cannot persist. The resolution clarifies that the Court’s silence on Ayala’s liability in the dispositive portion of G.R. No. L-20950 was a deliberate negation, not an omission, as the substantive right to damages against any party ceased to exist upon the finding of the Dizons’ good faith. Therefore, Tolentino cannot collect the awarded sum from Ayala.