GR 100156; (June, 1994) (Digest)
G.R. No. 100156 June 27, 1994
ISIDORA SALUD, petitioner, vs. THE COURT OF APPEALS and MELANIA GUERRERO, respondents.
FACTS
Petitioner Isidora Guerrero Salud and her late husband Eusebio B. Salud were the registered co-owners of an undivided one-half share in certain parcels of land in Bacoor, Cavite (Poblacion, Habay, and San Nicolas properties), with the other half owned by her brother Clemente Guerrero (husband of private respondent Melania Guerrero). On October 20, 1967, petitioner and her husband sold their share in the Poblacion and Habay properties to their children. On November 3, 1967, they sold their share in the San Nicolas property to other children. The deeds were not registered, and the couple continued to possess and exercise acts of ownership over the properties. On June 4, 1980, Clemente Guerrero filed two complaints to exercise his right of legal redemption as a co-owner. In Civil Case No. 3022 (involving Poblacion and Habay properties), the defendants (petitioner’s children) were declared in default, and a decision granting Guerrero’s right to redeem was rendered, which became final. Petitioner’s motion to intervene was denied. In Civil Case No. 3023 (involving San Nicolas property), the complaint was tried on the merits and dismissed, with the court holding the right of redemption was not in esse. To frustrate the redemption right granted in Civil Case No. 3022, petitioner filed Civil Case No. BCV-86-60 (Action to Quiet Title) against Melania Guerrero. The trial court dismissed the complaint on grounds of res judicata, which the Court of Appeals affirmed.
ISSUE
Whether the doctrine of res judicata applies to bar petitioner’s action to quiet title, considering she was not a party in the prior case (Civil Case No. 3022) where the judgment was rendered by default against her children.
RULING
No. The Supreme Court reversed the Court of Appeals and held that res judicata does not apply. The Court emphasized that the doctrine should not be rigidly applied where it would result in injustice. Petitioner was not a party in Civil Case No. 3022; her attempt to intervene was denied, and she was never given an opportunity to contest the claim. The judgment in that case was obtained by default against her children, who were then in the United States. In contrast, in Civil Case No. 3023, where one defendant answered and the case was tried, the court found no right of redemption existed. Applying res judicata to a non-party like petitioner would sacrifice justice to technicality and violate due process. The demands of due process outweigh the preclusive effect of a default judgment against non-parties. The case was remanded to the trial court for further proceedings.