GR L 4926; (December, 1908) (Digest)
G.R. No. L-4926
December 17, 1908
GREGORIO DE LEON, plaintiff-appellee, vs. PADRE SATURNINO TRINIDAD, defendant-appellant.
FACTS:
Gregorio De Leon (plaintiff-appellee) filed an action in the Court of First Instance in 1908 concerning the possession of a piece of land. The lower court found that De Leon had been in possession of the land for over twenty years and was the sole person with an interest in that specific tract, despite claims that his father and five children had possessed it.
Prior to this case, in 1907, Padre Saturnino Trinidad (defendant-appellant) commenced a forcible entry and detainer (FED) proceeding against De Leon in a justice of the peace court. Trinidad obtained a judgment in that FED case and was subsequently put in possession of the property. In the present appeal before the Supreme Court, Trinidad argued that the judgment from the earlier FED case was conclusive as to the rights of the parties and should bar De Leon’s current action in the Court of First Instance.
ISSUE:
Whether a prior judgment rendered in a suit of unlawful entry and detainer is conclusive as to the rights of the parties and bars a subsequent action in the Court of First Instance respecting title to the land or building.
RULING:
No. The Supreme Court held that a judgment rendered in a suit of unlawful entry and detainer is not conclusive as to the rights of the parties concerning title to the land and does not bar a subsequent action in the Court of First Instance.
Citing Section 87 of the Code of Civil Procedure, the Court affirmed that: “A judgment rendered in a suit of unlawful entry and detainer, either for the plaintiff or defendant, shall not bar an action in the Court of First Instance between the same parties respecting title to the land or building; nor shall any judgment given therein be held conclusive of the facts found in another action between the same parties.”
Therefore, the prior forcible entry and detainer judgment obtained by Padre Saturnino Trinidad did not preclude Gregorio De Leon’s action in the Court of First Instance nor was it conclusive on the issue of title. The Supreme Court sustained the lower court’s factual findings regarding De Leon’s long-term possession and sole interest in the land, and affirmed the judgment of the court below.