G.R. No. L-3397 July 27, 1951
Basilio Aquino, plaintiff-appellant, vs. Jose G. Sanvictores and Pastor Pangilinan, defendants-appellees.

FACTS

Basilio Aquino appealed from a resolution of the Court of First Instance of Bulacan dismissing his complaint against Jose G. Sanvictores and Pastor Pangilinan on the ground of res judicata, based on a judgment in a previous case (Civil No. 61). That previous case, finally decided by the Court of Appeals on November 29, 1948, involved the possession of Lot No. 19, Block 83 of the Hacienda de Buenavista, where Aquino was plaintiff and Pangilinan was defendant. The Court of Appeals declared Pangilinan the owner entitled to possession. It found that Aquino originally occupied the lot as a tenant or lessee. On March 4, 1939, the entire Hacienda de Buenavista was leased to the Commonwealth Government, with an option to purchase. The Commonwealth, through the Rural Progress Administration, subleased the lot to Aquino under a contract executed on December 18, 1939. Due to Aquino’s refusal to pay rent, the administrator of the Hacienda cancelled this sublease on April 17, 1940. Subsequently, on May 16, 1940, the administrator executed a “Compromiso de Venta” in favor of appellee Pangilinan, and after the Commonwealth Government acquired ownership, a deed of absolute sale was executed in Pangilinan’s favor. The Court of Appeals also found that on July 15, 1944, Aquino voluntarily relinquished possession of the land in favor of Pangilinan. Notwithstanding this adjudication, Aquino initiated the present litigation on May 24, 1949, alleging that Sanvictores (the manager/administrator of the hacienda), with the connivance of Pangilinan, arbitrarily cancelled his lease contract and ejected him by force from the land, which Pangilinan has since possessed, causing him damages. The prayer sought restitution of possession plus damages.

ISSUE

Whether the dismissal of Aquino’s complaint on the ground of res judicata was proper.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed the lower court’s resolution, holding that the present action was barred by res judicata. The Court ruled that both cases referred to the same particular lot. The present complaint alleged illegal cancellation of the lease and forcible deprivation of possession by Sanvictores in connivance with Pangilinan, which were the same allegations made in the previous case. However, the Court of Appeals had already found that Aquino was lawfully ejected due to his refusal to pay rent and that he voluntarily relinquished the land to Pangilinan, who purchased it from the Government. In the first case, Aquino demanded possession based on his lease contract and lost. In this second case, he again invoked the identical lease contract to plead for restitution. This demand was inconsistent with the prior verdict upholding the cancellation of that very lease contract and declaring Pangilinan the owner entitled to possession. The Court cited the general rule that a final judgment should be regarded as conclusive and set the controversy at rest. As to identity of parties, while Sanvictores was not a party to the first case, Aquino could and should have made him a party defendant therein, as the complaint contained identical imputations. A plaintiff should not be permitted to escape the effects of a previous judgment by adding a person who was virtually a party to the prior litigation. The Court applied the rule regarding co-owners and joint tort-feasors, stating that a judgment in a suit against one is res judicata in a subsequent suit against the same defendant joined with others. The Court also cited American jurisprudence that it is no objection to the application of res judicata that the action included additional parties not joined in the present suit or that there are additional parties in the present action.