G.R. No. 229070. November 10, 2020 (Case Brief / Digest)

**Title:** Heirs of Enrique Abad vs. Heirs of Jose Eusebio Abad Gallardo: Reaffirming Principles on Judgment on the Pleadings and Res Judicata

The dispute concerns a parcel of land (Lot 5826-B) in Capiddigan, Cordon, Isabela, part of a larger estate inherited by the children of Miguel Abad and Agueda de Leon: Dionisio, Isabel, and Enrique Abad. Allegedly, an extrajudicial settlement adjudicated the land to Enrique, leading to litigation (Civil Case No. 0591) between Enrique and his siblings, Dionisio and Isabel. The case saw various developments, including a claimed but unsubstantiated compromise agreement, leading to its eventual dismissal. Post the dismissal, a deed of partition ostensibly divided the property among the siblings, though it was never effectuated in the land titles.

Years later, in possession of the contested land piece (transferred to Jose Eusebio Abad Gallardo via donation from Isabel and later sought by his heirs), a series of legal confrontations ensued. The heirs of Jose Eusebio initiated a complaint for specific performance, surrender of title, redemption, consignation, and damages against the heirs of Enrique, leading to the questioned RTC resolutions that favored Jose Eusebio’s heirs based on judgment on the pleadings and the doctrine of res judicata. The heirs of Enrique challenged this decision, bringing the case to the Supreme Court.

1. Whether the RTC erred in granting judgment on the pleadings despite the alleged raising of genuine issues in the heirs of Enrique’s answer.
2. Whether the doctrine of res judicata was properly applied in the case at hand, barring the heirs of Enrique from contesting the ownership of the subject lot.
3. Whether the principle of judgment on the pleadings was correctly invoked given the circumstances.

**Court’s Decision:**
The Supreme Court ruled in favor of the heirs of Enrique, finding that the RTC’s application of both the doctrine of res judicata and judgment on the pleadings were erroneous.

1. **On judgment on the pleadings:** The Court held that the answer submitted by the heirs of Enrique did in fact raise genuine issues that needed a trial to be resolved, effectively making judgment on the pleadings inappropriate. The petitioners did not admit the material allegations against them, thereby requiring a full examination of the facts.
2. **On res judicata:** The Supreme Court determined that the dismissal of Civil Case No. 0591 did not constitute a judgment on the merits that could trigger res judicata. There was no final adjudication regarding the property’s partition, thus no bar to re-litigating the issues related to it.

The rulings reiterated the precepts governing judgment on the pleadings and res judicata: Judgment on the pleadings is inappropriate when the answer raises genuine issues, and res judicata requires a final judgment on the merits among its criteria, which was not met in this case due to the procedural history of Civil Case No. 0591.

**Class Notes:**
– **Judgment on the Pleadings:** An answer that raises genuine issues over material facts prevents the court from resolving the case through judgment on the pleadings.
– **Res Judicata:** Requires (a) a final judgment on the merits; (b) by a court with appropriate jurisdiction; (c) involving the same parties or their privies; and (d) concerning the same cause of action.
– **Specific Denials:** Failure to specifically deny allegations concerning documents’ genuineness and execution necessitates proof by the alleging party, especially if the parties to the current action were not parties to the document.

**Historical Background:**
The case underscores the complexity of inheritance disputes within families, especially regarding real property. It highlights how misunderstandings and informal settlements can lead to prolonged litigation. Moreover, it reflects the evolving jurisprudence on procedural matters like judgment on the pleadings and doctrine of res judicata in the Philippine legal system.


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