GR 126640; (November, 2000) (Digest)
G.R. No. 126640 ; November 23, 2000
SPOUSES MARCELO B. ARENAS and ANITA T. ARENAS, petitioners, vs. THE HON. COURT OF APPEALS, SPOUSES CONRADO S. ROJAS AND ROSALINA BAUZON ROJAS, respondents.
FACTS
Respondent Rosalina Rojas, co-owner of a building, verbally leased a stall to petitioner Marcelo Arenas on a month-to-month basis for his optical clinic. In 1990, Rojas decided to demolish and reconstruct the building, sending a notice to terminate the lease and demanding vacation by January 1991. Arenas refused to vacate. Consequently, Rojas filed an ejectment case (Civil Case No. 658) with the Municipal Trial Court (MTC). Arenas answered, interposing a counterclaim for moral and exemplary damages, alleging the suit was malicious. The MTC ruled for Rojas, ordering Arenas to vacate and pay litigation costs, while dismissing his counterclaim for lack of evidence. Arenas appealed this to the Regional Trial Court (RTC).
While the ejectment appeal was pending, the Arenas spouses filed a separate complaint for damages (Civil Case No. 16890) with another RTC branch. They alleged that during the pendency of the ejectment case, the Rojas spouses committed harassing acts such as removing their signboard, dumping gravel and sand in front of the stall, posting a “no trespassing” sign, and cutting off electricity to force them out, causing business losses and moral damages. The RTC hearing the damages case ruled in favor of the Arenases, awarding actual, moral, and exemplary damages.
ISSUE
Whether the filing of the separate action for damages (Civil Case No. 16890) is barred by the prior ejectment case where the petitioners had already interposed a counterclaim for damages.
RULING
The Supreme Court affirmed the Court of Appeals’ dismissal of the separate damages action. The legal logic is anchored on the rule against splitting a cause of action and the doctrine of res judicata. A cause of action cannot be divided into parts and made the subject of separate suits. The alleged harassing acts of the respondents—removing the signboard, dumping gravel, cutting electricity—were committed during the pendency of the ejectment case. These acts were intrinsically related to the lessor-lessee relationship and the dispute over possession, which was the core issue in the ejectment suit.
Crucially, petitioners had already raised the issue of malicious filing and sought moral and exemplary damages via their counterclaim in the very same ejectment proceeding. By choosing to litigate their claim for damages arising from the ejectment suit within that suit itself, they were precluded from instituting a separate and subsequent action for the same cause. The MTC’s dismissal of their counterclaim “for lack of evidence” constituted a judgment on the merits of that claim. Therefore, the finality of that dismissal, upon the conclusion of the ejectment proceedings, barred the subsequent damages case under the principle of res judicata. The proper remedy was to pursue their damages claim within the appealed ejectment case, not to initiate a separate action.