G.R. No. L-30892, March 25, 1930
INES MELGAR and PEDRO NOEL, plaintiffs-appellees, vs. TOMAS DELGADO and ALBERTA ALQUIZOLA, defendants-appellants.

FACTS

Plaintiffs Ines Melgar and Pedro Noel filed an action for recovery of possession and damages against defendants Tomas Delgado and Alberta Alquizola. Ines Melgar claimed to be a testamentary heir of her father Juan Melgar and alleged that the defendants fraudulently took possession of a 105-hectare portion of her inherited land nine years prior. The defendants raised the defenses of res judicata and prescription, citing a prior case (Civil Case No. 338) where Tomas Delgado had sued for partition of the same land against Diosdado Melgar (as administrator of Juan Melgar’s estate) and Ines Melgar. In that prior case, Ines Melgar was declared in default for failure to answer an amended complaint, and a judgment was rendered. The Court of First Instance ruled in favor of the plaintiffs in the present case, ordering the defendants to deliver the land and pay annual damages.

ISSUE

Whether the present action is barred by res judicata due to the prior judgment in Civil Case No. 338.

RULING

Yes, the action is barred by res judicata. The Supreme Court reversed the lower court’s decision and dismissed the case. The Court held that the prior case involved the same parties, the same subject matter (the land in question), and the same cause of action (ownership and possession). Ines Melgar was a party in the prior case, having been personally served with summons and represented by counsel. Her default judgment in that case constituted a final adjudication on the merits. The Court also noted that the plaintiffs’ claim of fraud in the prior case was barred by laches and prescription, as the action was filed more than seven years after the alleged discovery of fraud, exceeding the four-year limitation period. Thus, the principle of res judicata precludes relitigation of the same issues.