G.R. No. 8821; September 24, 1915
BIBIANA ISAAC, ET AL. vs. FILOMENA PADILLA, administratrix of the estate of the deceased Feliciano Padilla

FACTS:
On October 11, 1884, Feliciano Padilla executed a document stating he sold a parcel of rice land to Manuel Abella under a pacto de retro (sale with right of repurchase) for P1,000, with the condition that Padilla would till the land for two years and pay an annual rent of 5,000 gantas of rice. The redemption period expired on October 11, 1886, but Padilla did not repurchase the land. Despite this, he remained in possession. After Abella’s death in 1896, his heirs (the plaintiffs) claimed ownership of the land by inheritance. Padilla died in 1897, and his heirs, later represented by the defendant administratrix, continued possession. The land was included in the inventory of Padilla’s estate.

In 1908, the plaintiffs, as Abella’s heirs, filed a money claim against Padilla’s estate for P6,000, based on a liquidation account that treated the original transaction as a money debt. This claim was denied by the Court of First Instance on the ground of prescription, and the plaintiffs’ appeal from this denial was later withdrawn, making the order final.

Subsequently, the plaintiffs filed the present action for recovery of possession (reivindicacion) of the land and for payment of accrued rents.

ISSUE:
Whether the plaintiffs’ action for recovery of possession is barred by the principle of res judicata, or is otherwise without merit based on the nature of the obligations between the parties.

RULING:
The Supreme Court AFFIRMED the trial court’s dismissal of the complaint, but on grounds different from res judicata.

The judgment of the lower court was affirmed, with costs against the plaintiffs-appellants.