G.R. No. L-9225, December 24, 1914
JULIANA SOLANO, ET AL., plaintiffs-appellants, vs. VICENTA SALVILLA, ET AL., defendants-appellees.

FACTS:
Macario Samson filed an action for recovery of possession of a tract of land against Vicenta Salvilla and Pascual Sierra. The trial court absolved the defendants, but on appeal, the Supreme Court reversed the decision and declared Samson the owner, ordering the defendants to restore possession. The Supreme Court also absolved the defendants from paying P1,000 in damages, as Samson failed to prove their existence or amount. After the Supreme Court decision, Macario Samson died. His heirs (Juliana Solano and children) filed a new action to recover rents from the defendants for the years 1907, 1908, and 1909, representing one-third of the crops harvested during those years, valued at P1,240.80. The defendants pleaded res adjudicata, arguing that the claim for rents was already included and decided in the prior recovery case. The trial court dismissed the complaint, sustaining the plea of res adjudicata.

ISSUE:
Whether the claim for rents (or a share of the crops) for the years 19071909 is barred by res adjudicata, having been included in the prior recovery case where damages were claimed but not awarded.

RULING:
No. The Supreme Court reversed the trial court’s dismissal and remanded the case for trial.

The Court held that for res adjudicata to apply, there must be identity of parties, subject matter, and cause of action between the prior and subsequent cases. While there was identity of parties (the defendants are the same, and the plaintiffs are successors-in-interest of Macario Samson) and identity of cause of action (both arising from the defendants’ unlawful possession), there was no identity of subject matter.

In the first case, the claim for damages (P1,000) referred to injuries suffered from the usurpation up to the filing of the complaint in 1906. In the second case, the claim was for rents (a share of the crops) for the years 19071909, covering the period after the first complaint was filed until possession was restored in 1909. These are distinct subject matters: the first concerned pre-complaint damages, while the second concerned post-complaint fruits or rents derived from the land during the defendants’ continued unlawful possession.

Since the claim for rents for 19071909 was not made nor decided in the prior case, it is not barred by res adjudicata. The case was returned to the trial court for reception of evidence on the plaintiffs’ claim for rents.