G.R. No. 37874 ; September 22, 1933
Braulio Balagtas, et al. vs. Ciriaca Arguelles

FACTS

The plaintiffs-appellants, Braulio Balagtas and others, filed an action for damages against the defendant-appellee, Ciriaca Arguelles. They sought to recover the value of their houses and building materials that were constructed on Arguelles’s registered land but were later destroyed by the sheriff upon her order. They alleged Arguelles appropriated these items. This was the third case between the parties. The first case involved the land registration proceedings where Arguelles obtained title. The second case (G.R. No. 35029) definitively ruled that the plaintiffs were not entitled to indemnity for the improvements because they failed to assert that right during the registration proceedings. That second decision, however, granted them a concession—the right to remove their houses and materials from the land—based on Arguelles’s expressed willingness to allow removal, not payment.

ISSUE

Whether the plaintiffs have a cause of action to recover the value of the improvements (houses and materials) that were allegedly appropriated by the defendant after the prior final judgment.

RULING

No. The Supreme Court affirmed the trial court’s dismissal of the complaint. The doctrine of res judicata bars the present action. The right to indemnity for the improvements was already adjudicated adversely against the plaintiffs in the second case (G.R. No. 35029). The concession granted to them in that prior judgment was merely a right to remove the improvements, not a right to be paid for them. That concession ceased to exist once the houses and materials disappeared or were appropriated. To allow this new action would circumvent the finality of the prior judgment and promote endless litigation. The demurrer was correctly sustained as the complaint itself revealed the existence of res judicata.

AI Generated by Armztrong.