BautistavLindo

Facts: Alfredo R. Bautista (Bautista), petitioners predecessor, inherited in1983 a freepatent land. A few years
later, he subdivided the property and sold it toseveralvendees,hereinrespondents,viaanotarizeddeedofabsolute
sale. Three years afterthe sale, or onAugust5,1994,Bautistafiledacomplaintforrepurchaseagainstrespondents,
anchoring his cause of action on Section 119of CommonwealthActNo. (CA)141,otherwiseknownasthePublic
Land Act, which reads: SECTION 119. Every conveyance of land acquired under the free patent or homestead
provisions, when proper,shallbesubjecttorepurchasebytheapplicant,hiswidow,or legalheirs,withinaperiodof
fiveyears from the date of theconveyance. Respondents, intheir Answer, raisedlackofcause ofaction,estoppel,
prescription,andlaches,asdefenses.

Respondents Francisco and Welhilmina Lindo laterenteredinto acompromiseagreementwith petitioners,whereby

they agreed to cede toEpifania athree thousand two hundred and thirty square meter (3,230 sq.m.)portion of the
property as well as towaive,abandon,surrender,andwithdraw allclaimsandcounterclaimsagainsteachother. The
compromisewasapprovedbytheRTCinitsDecisiondatedJanuary27,2011.

Other respondents,however, filedaMotionto Dismiss4datedFebruary4,2013,allegingthatthecomplaintfailedto

state thevalue ofthe property soughtto berecovered. Moreover, they asserted that the total sellingpriceofallthe
properties is only sixteen thousand five hundred pesos (PhP 16,500), and the selling price or market value of a
property is always higher than its assessed value. Since Batas Pambansa Blg. (BP) 129, as amended, grants
jurisdictionto the RTCs over civil actions involvingtitle to or possession of realpropertyorinterestthereinwhere
the assessed value is more than PhP 20,000, then the RTC has no jurisdiction overthe complaintin questionsince
thepropertywhichBautistaseekstorepurchaseisbelowthePhP20,000jurisdictionalceiling.

RTC issued the assailedorder dismissing the complaint for lack of jurisdiction. The trial court found that Bautista
failedtoallegeinhiscomplaintthatthevalueofthesubjectpropertyexceeds20thousandpesos.

Issue: WON the action filed by petitioners is one involving title to or possession of real propertyor any interest
thereinoroneincapableofpecuniaryestimation.

Held: The Court rules that the complaint to redeem a land subject of a free patent is acivil action incapable of
pecuniary estimation. The facts are clear that Bautista sold to respondents his lots which werecovered by a free
patent. While the deeds of sale do not explicitlycontain the stipulation that thesale is subjecttorepurchasebythe
applicant within a period of five(5) years from the date of conveyance pursuantto Sec. 119 ofCA141, still,such
legal provision isdeemedintegratedandmadepartofthedeedofsaleasprescribedbylaw. Itisbasicthatthelaw is
deemed written into every contract. At first blush, it appears that the action filed by Bautista involves title to or
possession of the lotshesoldtorespondents.Sincethetotalsellingprice islessthanPhP20,000,thentheMTC,not
the RTC, has jurisdiction overthe case. This propositionis incorrectforthereacquisitionofthelotsbyBautistaor
herein successorsininterests,the present petitioners, is but incidentaltoandan offshootoftheexerciseoftheright
by thelattertoredeem saidlotspursuantto Sec.119ofCA141.Thereconveyanceofthetitleto petitionersissolely
dependent on the exercise of such right to repurchase the lots in question and is not the principalor main relief or
remedy sought. Thus, theactionofpetitionersis,inreality,incapableofpecuniaryestimation, andthereconveyance
of the lot is merely the outcome of the performance of the obligation to return the property conformably to the
express provision of CA 141. Evenif we treatthepresentactionasoneinvolvingtitle torealpropertyoraninterest
therein which falls under the jurisdiction of the firstlevelcourtunderSec.33ofBP129,asthetotalsellingpriceis
onlyPhP 16,000 way belowthe PhP 20,000 ceiling,still, the postulation of respondents that MTChasjurisdiction
will not hold water. This is because respondents have actually participated in theproceedings before the RTC and
aggressivelydefended their position, and by virtue of which they arealready barred to question the jurisdiction of
theRTCfollowingtheprincipleofjurisdictionbyestoppel.

MarilagvMartinez

Facts: On July 30, 1992, Rafael Martinez (Rafael), respondent's father, obtained from petitioner a loan in the
amount of P160,000.00, with a stipulated monthlyinterest of fivepercent (5%), payable within a period of six (6)
months. The loan was securedby a real estate mortgage over a parcelof land. Rafael failed to settlehisobligation
upon maturity and despite repeated demands, prompting petitioner tofile a Complaint for Judicial Foreclosure of
Real Estate Mortgage before theRTCofImus,Cavite.Rafaelfailedtofile hisanswerand,uponpetitioner'smotion,

was declared in default. After an ex parte presentationofpetitioner's evidence, the RTCImus issuedaDecision9
dated January 30, 1998, (January 30, 1998 Decision) in theforeclosure case, declaring thestipulated 5% monthly
interest to be usurious and reducing the same to 12% per annum (p.a.). Accordingly, it ordered Rafael to pay
petitioner the amount of P229,200.00, consistingoftheprincipalofP160,000.00andaccruedinterestofP59,200.00
fromJuly30,1992toSeptember30,1995.10RecordsdonotshowthatthisDecisionhadalreadyattainedfinality.

Meanwhile, prior to Rafael's notice ofthe abovedecision,respondentagreedtopayRafael'sobligationtopetitioner

which was pegged at P689,000.00. After making a total payment of P400,000.00,11 he executed a promissory
note12 dated February 20, 1998 (subject PN), binding himself topay on or before March 31, 1998 theamountof
P289,000.00, "representing the balance of the agreed financial obligation of [his] father to [petitioner]."13After
learningof the January 30, 1998 Decision, respondent refused to paytheamountcoveredbythesubjectPNdespite
demands,prompting petitioner tofile a complaint14 for sum of money and damagesbeforethecourtaquoonJuly
2, 1998, docketed as Civil Case No. 980156 (collection case). Respondent filed his answer,15 contending that
petitioner has no cause of action against him. He averred thathe has fully settled Rafael's obligation andthathe
committed a mistake in paying more than the amount due under the loan, i.e., the amount of P229,200.00 as
adjudgedbytheRTCImusinthejudicialforeclosurecasewhich,thus,warrantedthereturnoftheexcesspayment.

Issue:WONresjudicatawouldapply

Held: No. A case is barred by prior judgment orresjudicatawhenthe followingelementsconcur:(a)thejudgment

sought to bar the new action must be final(b) the decision must have beenrenderedbyacourthavingjurisdiction
overthesubjectmatterandtheparties (c)the dispositionofthecasemustbeajudgmenton themeritsand(d) there
must be as between the first and second action, identity of parties, subject matter, and causes of action. This is
because the recordsare bereft of any indicationthatthe August 28, 2003 Decision in the judicial foreclosurecase
had already attained finality, evidenced, for instance, by a copy of the entry of judgment in the said case.
Accordingly,withtheveryfirstelementofresjudicatamissing,saidprinciplecannotbemadetoobtain.

Thisnotwithstanding, the Court holds that petitioner's prosecution of thecollectioncasewasbarred,instead,bythe

principle of litis pendentia inview ofthe substantial identityofpartiesand singularity ofthecausesofactioninthe
foreclosure and collection cases, suchthatthe prior foreclosure casebarredpetitioner's recourse to the subsequent
collectioncase.

To lay downthebasics,litispendentia,asagroundforthedismissalofacivilaction,refersto that situationwherein

anotheraction ispendingbetweenthesamepartiesforthesamecauseofaction,suchthatthesecondactionbecomes
unnecessary and vexatious. For the bar of litispendentia to be invoked,the following requisites must concur: (a)
identity of parties, or at least such parties as represent the same interests in both actions (b) identity of rights
asserted and relief prayed for, therelief being founded on thesame facts and (c) the identity ofthetwopreceding
particulars is such that any judgment rendered in the pending case,regardlessof which partyis successful would
amounttoresjudicataintheother.

In the present case, records show that petitioner, as creditor mortgagee, institutedan action forjudicialforeclosure
pursuant to the provisions of Rule 68 of the Rules of Court in order to recover on Rafael's debt.In light of the
foregoing discussion,the availment ofsuch remedy thus bars recourse to the subsequent filingofapersonal action
for collection of the same debt, in this case, under theprinciple of litis pendentia, considering that theforeclosure
caseonlyremainspendingasitwasnotshowntohaveattainedfinality.