G.R. No. L-15260; August 18, 1920
FAUSTO RUBISO, plaintiff-appellant, vs. FLORENTINO RIVERA, ET AL., defendants-appellees.

FACTS:
Fausto Rubiso and Florentino Rivera were involved in prior litigation over the ownership of the pilot boat Valentina. Rivera purchased the boat from Sy Qui on January 4, 1915, but did not inscribe his title in the mercantile registry. Rubiso later acquired the same boat at a public auction on January 23, 1915, and duly inscribed his title on March 4, 1915. The Court of First Instance of Manila decided in favor of Rubiso on September 6, 1915, declaring him the owner. This judgment was affirmed by the Supreme Court on October 30, 1917. When the judgment was executed, the sheriff could only deliver to Rubiso the pilot boat in a seriously damaged condition and two useless sails.

Rubiso then filed the present action to recover damages amounting to P1,200, alleging that the destruction and loss of the boat and its equipment were due to the fault and negligence of Rivera and others. The trial court rendered judgment in favor of the defendants, absolving them of liability. Rubiso appealed.

ISSUE:
Whether the plaintiff-appellant, Fausto Rubiso, is entitled to recover damages for the alleged destruction and loss of the pilot boat Valentina and its equipment from the defendants-appellees.

RULING:
The Supreme Court affirmed the judgment of the lower court, absolving the defendants. The Court held that:
1. The plaintiff failed to present satisfactory evidence to prove the existence and amount of the damages claimed. Testimony from both plaintiff and defense witnesses indicated the boat was in a seriously damaged and unseaworthy condition long before Rubiso’s acquisition and the execution of judgment, and had no legal value by August 1915.
2. The defense of res judicata barred the present action. The claim for damages was essentially the same as that raised in the prior ownership case (G.R. No. 11407), where the Supreme Court had already ruled that Rivera did not act in bad faith and that there was no positive proof of the amount of damages. A judgment for damages (or the denial thereof) in a prior action concerning the same property constitutes a bar to a subsequent suit for the recovery of the same damages between the same parties.
3. The evidence showed the boat’s deterioration occurred while it was stranded and exposed to the elements awaiting the final judgment, circumstances beyond Rivera’s control, and not due to his fault or negligence.

Therefore, the appeal was dismissed, and costs were assessed against the appellant.