Case Name Carlet v CA

G.R. No. 114275

Ponente: Romero, J.

Facts:

In 1917, a Transfer Certificate No. 1599 was issued in Jose Sevillas
name after payment of the full purchase price of Lot 981 of the Bian
Estate in Laguna, with an area of 864 square meters.
In 1949, Pablo Sevillo, one of Joses four sons with a wife and four
children of his own, declared the lot for taxation purposes even if the
property was still in Jose Sevillos name.
In 1955, Pablo, by then a widower, married Candida Baylo who had a
previous daughter already married named Cirila Baylo Carolasan. The
union produced no offspring.
In 1965, Pablo Sevillo, with Candida Baylo, filed a petition before the
Court of First Instance for reconstitution of title. Reconstitution was
allowed and a TCT was issued in the name of Pablo Sevillo, married to
Candida Baylo. Pablo Sevillo and his wife died in 1967 and in 1974,
respectively.
Before dying, Candida Baylo executed a Deed of Sale in favor of Pablos
former children in his previous marriage.
In 1980, the heirs of Cirila Baylo Carolasan, all surnamed Zarate and
herein private respondents, filed a case for annulment of the said Deed
of Sale. The case was docketed as Civil Case No. B-1656 before the
Court of First Instance of Bian, Laguna.
The Deed of Sale was rendered as null and void and of no force and
effect, and the representative of the estate of the plaintiff Cirila Baylo
Carolasan and the defendants Gregorio Sevillo, Samero Sevillo, Maltin
Sevillo, Andrea Sevillo and Isidro Zamora, as the surviving spouse of
Consolacion Sevillo, are hereby ordered to partition Lot No. 981.
The losing party, the Sevillos then filed several cases to annul the
decision to the IAC and the SC, all of which were denied.
On July 10, 1991, petitioner Iigo F. Carlet, as special administrator of
the estate of Pablo and Antonia Sevillo, filed the case at bar, an action
for reconveyance of property, docketed as Civil Case No. B-3582,
against the heirs of Cirila.
Defendants Zarate moved to dismiss the case on the ground of res
judicata. The Defendants won and now Carlet has appealed to the CA.

Issues:
Whether or not the case should be dismissed on the ground of res
judicata.

Held/Ratio:
NO. It was already decided in Civil Case No. B-1656. Res
Judicataaaaaa!!!!! There are four requisites to successfully invoke res
judicata: (a) finality of the former judgment; (b) the court which
rendered it had jurisdiction over the subject matter and the parties; (c)
it must be a judgment on the merits; and (d) there must be between the
first and second actions identity of parties, subject matter and cause of
action. A judgment on the merits rendered in the first case constitutes
an absolute bar to the subsequent action when the three identities are
present. Even though Civil Case No. B-3582 was initiated by
petitioner as administrator of the estate of Pablo and Antonia
Sevillo, the fact remains that he represents the same heirs.

Final Ruling:

THE PETITION IS DENIED. RES JUDICATA!!

Recit-Ready Digest:

Heirs of Cirila Baylo Carolasan, under the surname Zarate, filed a case for
annulment for a Deed of Sale in order for them to be the rightful owners of a
lot in Laguna. The case was docketed as Civil Case No. B-1656. They won
and the deed was rendered null and void.

The losing party, the Sevillos, filed several cases to overturn the decision, all
of which were dismissed. On 1991, Carlet, filed for reconveyance of property
as a special administrator of the lot in favor of the Sevillos, docketed as Civil
Case No. B-3582. Defendants Zarate moved to dismiss the case on the
ground of res judicata. The Defendants won and now Carlet has appealed to
the CA. The previous decision won and the appeal is dismissed.

Even though Civil Case No. B-3582 was initiated by petitioner as
administrator of the estate of Pablo and Antonia Sevillo, the fact
remains that he represents the same heirs. This still constitutes res
judicata.

When material facts or questions which were in issue in a former action and
were admitted or judicially determined there are conclusively settled by a
judgment rendered therein, such facts or questions become res judicata and
may not again be litigated in a subsequent action between the same parties
or their privies regardless of the form of the latter. This is the essence of res
judicata or bar by prior judgment.

When material facts or questions which were in issue in a former action and
were admitted or judicially determined there are conclusively settled by a
judgment rendered therein, such facts or questions become res judicata and
may not again be litigated in a subsequent action between the same parties or
their privies regardless of the form of the latter. This is the essence of res
judicata or bar by prior judgment.