G.R. No. 238095 , August 20, 2025
ANGELITO O. HAO, PETITIONER, vs. JENNIFER LAGAHID, ALSO KNOWN AS “JENNIFER LAGAHID-HAO,” RESPONDENT.

FACTS

Samson Eng Guan Hao died on August 24, 2007. Respondent Jennifer Lagahid, claiming to be Samson’s lawful wife and mother of his minor son Ace, executed an Affidavit of Self-Adjudication over Samson’s properties and filed an Omnibus Petition for the replacement of lost owner’s duplicate copies of titles. The trial court granted the petition. Petitioner Angelito O. Hao, Samson’s brother, filed a Petition for Relief from Judgment, alleging the titles were not lost but in his possession and that Jennifer fraudulently misrepresented herself as Samson’s spouse, supported by certifications showing no record of their marriage. The trial court granted the petition, declared its previous order void, and reinstated the original titles. Angelito then filed a criminal complaint for perjury against Jennifer and a separate civil complaint for damages based on her false claims. The Regional Trial Court ruled in favor of Angelito, awarding him various damages. The Court of Appeals reversed the trial court, dismissing the civil complaint on the grounds of res judicata and/or litis pendentia. It held that Angelito’s claim for damages arising from the petition for new titles should have been a compulsory counterclaim in that proceeding, and his claim for damages arising from the perjury cases was deemed instituted with the criminal action.

ISSUE

Whether the Court of Appeals erred in dismissing Angelito Hao’s civil complaint for damages on the grounds of res judicata and/or litis pendentia.

RULING

Yes. The Supreme Court reversed the Court of Appeals and reinstated the Regional Trial Court’s decision. The Court held that the civil action for damages was not barred. First, the summary proceeding for the issuance of new titles (Miscellaneous Case No. 2008-086) was not an appropriate venue for litigating a claim for damages under Article 21 of the Civil Code, as it was not an adversarial proceeding where a counterclaim could be filed. The grant of Angelito’s Petition for Relief from Judgment resulted in the dismissal of Jennifer’s petition, leaving no pending main action in which to file a counterclaim. Second, the civil liability from the perjury cases is separate from the civil liability arising from the same acts under Article 21 of the Civil Code. The civil action for perjury is deemed instituted with the criminal case, but a separate civil action for quasi-delict under Article 21 is allowed. Angelito’s civil complaint was precisely based on Article 21, alleging acts causing damage independent of the crime of perjury. Therefore, the separate civil action was proper and not barred.