G.R. No. L-9518; January 3, 1916

FACTS:
In 1905, two separate actions were filed in the justice’s court of Oas: one by Francisco Rosco and another by Ignacio Rosco, both against Mariano Rebueno and others. The justice’s court ruled in favor of the defendants in both cases. The plaintiffs appealed to the Court of First Instance (CFI) of Albay. After perfecting the appeals, their attorney filed a single complaint in the CFI joining both plaintiffs and all defendants from the two appealed cases. This new complaint included the original causes of action but added new allegations and demanded P2,300, a sum beyond the jurisdiction of a justice’s court. The CFI initially refused to try this new complaint as an original action, treating it instead as a continuation of the appeals. It proceeded to try only the case of Francisco Rosco vs. Mariano Rebueno, rendering a judgment for P300. On appeal, the Supreme Court reversed and remanded, holding that the CFI complaint was an original action, not a reproduction of the justice’s court complaints. On remand, the CFI tried the case as an original action. The defendant pleaded res judicata, arguing that the original judgments of the justice’s court were final and barred the new action.

ISSUE:
Whether the defense of res judicata is valid, i.e., whether the judgments of the justice’s court bar the subsequent original action in the Court of First Instance based on the same cause of action.

RULING:
No, the defense of res judicata is not valid. The Supreme Court affirmed the CFI’s judgment for the plaintiff. The Court held that the action in the CFI was an original and independent action, as previously established in the first appeal. Regarding res judicata, the Court examined the status of the justice’s court judgments. Under Section 75 of the Code of Civil Procedure in force at the time the appeals were perfected (1906), a perfected appeal operated to vacate the judgment of the justice of the peace. At that time, there was no statutory provision for the revival of such a judgment upon dismissal or abandonment of the appeal. Although Act No. 2111 (effective January 31, 1912) later amended the law to allow revival, it was not applicable to appeals taken in 1906. Consequently, when the appeals were taken, the justice’s court judgments were vacated and ceased to exist in contemplation of law. They could not, therefore, be pleaded as a bar to the subsequent original action. On the merits, the evidence supported the CFI’s findings. The judgment was affirmed.