GR L 19973; (April, 1965) (Digest)
G.R. No. L-19973 April 30, 1965
LORENZO E. MACANSANTOS and TOMAS E. MACANSANTOS, plaintiffs-appellants, vs. TEOFILA GUINOO and VICENTE GUINOO, defendants-appellees.
FACTS
Bernabe Macansantos and Felisa Enriquez, a married couple, acquired Lot No. 127 in Davao City. After Felisa’s death, Bernabe sold one-half of the lot (Lot 127-A) to Teofila de Guinoo and the other half to Honganji Mission. The children of Bernabe and Felisa, Lorenzo and Tomas Macansantos, filed suits to declare the sales void, claiming the lot was conjugal property and no liquidation had occurred. In a prior decision (G.R. No. L-5541), the Supreme Court ordered Teofila de Guinoo to reconvey one-half of Lot 127-A to Lorenzo and Tomas Macansantos. This decision became final. Disputes arose during execution regarding whether the reconveyance deed should mention a P400 consideration and exclude improvements. The trial court ordered the deed to be executed strictly per the Supreme Court decision, without consideration or mention of improvements. The Macansantos brothers then filed Civil Case No. 2061 for partition and recovery of rentals and damages. The trial court dismissed their claims for damages, rentals, and ownership of improvements, ordering only partition of the property. The Macansantos brothers appealed this decision.
ISSUE
Whether the issues concerning the appellants’ right to one-half of the improvements on Lot 127-A, plus damages and rentals, are already res judicata.
RULING
Yes. The Supreme Court affirmed the trial court’s decision. The Court held that the issues raised by the appellants regarding their claim to one-half of the improvements, damages, and rentals were already res judicata. This was based on the Court’s prior ruling in the mandamus case (G.R. No. L-13726), which determined that the final decision in G.R. No. L-5541 ordered only the reconveyance of one-half of the lot without any pronouncement on improvements, consideration, or rentals. The Court emphasized that the trial court had no authority to alter that final decision, and inserting provisions about considerations or improvements in the deed would constitute an unauthorized modification. Therefore, these matters could not be relitigated in the partition action.