Title

Abad vs. Heirs of Gallardo

Case Ponente Decision Date

G.R. No. 229070 (Resolution) CAGUIOA, J Nov 10, 2020

A legal dispute over the ownership and partition of a parcel of land is resolved by the Supreme Court,
ruling in favor of the petitioners and directing the lower court to hear and decide the case on the merits.

Case Digest (G.R. No. 229070)

Llama-3-70B (Latest)

Facts:
In the case of "Abad v. Heirs of Gallardo," the Supreme Court of the Philippines revisited a long-
standing dispute over a parcel of land, specifically Lot 5826-B, which measures 5,000 square
meters and is located in Capiddigan, Cordon, Isabela. The land was originally part of a larger estate
owned by Miguel Abad and Agueda de Leon, who bequeathed it to their children Dionisio, Isabel,
and Enrique Abad upon their demise. Subsequent to their inheritance, a deed was executed
transferring the entirety of the property to Enrique. This action sparked a legal contest when
Dionisio and Isabel disputed the validity of this deed, leading to a series of legal battles and a
compromise agreement that supposedly resolved the distribution of the property among the
siblings. However, the actual partition of the land was never executed, and the title remained under
Enrique’s name.

Isabel later passed away, leaving her share, identified as Lot 5826-B, to her son Jose Eusebio Abad
Gallardo via a deed of donation. This lot later became entangled in a loan transaction, which led to
further disputes over possession and ownership. The Heirs of Jose Eusebio initiated a lawsuit
against the Heirs of Enrique, demanding specific performance and recognition of the deed of
donation. The Regional Trial Court (RTC) initially ruled in favor of the Heirs of Jose Eusebio based
on the pleadings, ordering the Heirs of Enrique to adhere to the deed of partition and recognize the
deed of donation.

Issue:
1. Did the Regional Trial Court err in granting a motion for judgment on the pleadings without a
trial, despite the presence of contested issues raised by the Heirs of Enrique?
2. Does the doctrine of res judicata apply to the case, thereby preventing the re-litigation of issues
previously settled by a compromise agreement?

Ruling:
The Supreme Court reversed the decisions of the lower court. It ruled that the Regional Trial Court
indeed erred in granting the motion for judgment on the pleadings, as there were genuine issues of
fact raised by the Heirs of Enrique that necessitated a trial. Specifically, these issues pertained to
the authenticity and the legal effects of the compromise agreement and the subsequent deeds.
Consequently, the Supreme Court denied the motion for judgment on the pleadings and remanded
the case for a full trial.

Furthermore, the Court held that the doctrine of res judicata did not apply in this instance. The
previous cases involving the property had been dismissed without a trial on the merits and without
judicial approval of any compromise agreement, meaning there was no final judgment on the
merits that could conclusively determine the parties' rights to the property.

Ratio:
The Supreme Court's decision was grounded on the principle that justice must be served
substantively rather than merely procedurally. The Court emphasized that a judgment on the
pleadings is only appropriate when there are no genuine issues of fact to be tried. In this case, the
Heirs of Enrique raised substantial issues regarding the validity and effects of legal documents that
allegedly transferred ownership and partitioned the property. These issues required evidentiary
scrutiny and factual determination, which could only be adequately addressed at a trial.

Additionally, the Court clarified the application of the doctrine of res judicata, noting that for this
doctrine to apply, there must be a final judgment rendered by a competent court on the merits of
the case, which was absent in the prior disputes related to the property. Thus, the previous
litigation did not bar the re-litigation of the issues concerning the property's ownership and
partition.