4 ARREZA v. DIAZ
FACTS:
1. Bliss Development is the owner of a housing unit in
QC.
2. A case was instituted involving the conflict of
ownership between Arreza and Diaz.
3. Bliss filed a complaint for interpleader.
4. TC: Interpleader is resolved in favor of Arezza. This
became final and duly executed with Bliss executing a
Contract to Sell to Arezza. Diaz was constrained to
deliver the property with all its improvements to
Arreza.
5. Diaz filed a complaint against Bliss and Arreza seeking
to hold them liable to reimburse the cost of acquisition
and improvements on the property.
6. Arezza, MTD: Res judicata (interpleader case already
resolved) and lack of cause of action. Denied.
Reconsideration.
7. CA: Dismissed Arezzas MR. The decision invoked as
res judicata resolved only the issue of who between
Arezza and Diaz has the better right over the property
but not the rights and obligations of the parties.
ISSUE: Whether Diazs claims for reimbursement against
Arezza are barred by res adjudicata since the complaint for
interpleader had already been resolved. YES.
RATIO:
Elements for res adjudicata:
o Former judgment must be final
o Court which rendered judgment has jurisdiction
over the parties and the subject matter
o Must be a judgment on the merits
o There must be between the 1 st and 2nd causes of
action identity of parties, subject matter, and cause
of action.
The prior case for interpleader was settled with finality.
The judgment therein is now final.
RTC acquired jurisdiction over the parties and subject
matter.
6 OCAMPO v. TIRONA
FACTS:
1. Ocampo alleged that he is the owner of a parcel of
land in Pasay. He bought it from Breton, the heir of the
lots registered owner (Alipio Breton).
2. Possession and administration are already in Ocampos
management even though the TCT is not yet in his
name.
3. Tirona, is a lessee occupying a portion of the subject
land from Breton-Mendiola (another heir).
4. Ocampo gave a formal written notice to Tirona about
his acquisition of the lot.
5. Tirona paid some of the monthly rentals due to
Ocampo.
6. Ocampo later received a letter from Tironas counsel
saying that Tirona is invoking her right of first refusal
since the property was declared to be under priority
development and will temporarily stop paying for the
monthly rentals.
7. Ocampo demanded for the payment of rentals and for
Tirona to vacate the premises. Tirona failed to heed
the demands.
8. Ocampo filed a complaint for unlawful detainer against
Tirona.
9. Tirona: Yanezas (allegedly the true owner) attorney in
fact recognizes Tirona as a co-owner by possession
and ceded to transfer the parcel in Tironas favor.
a. Tirona does not want to pay Ocampo because
he is not the true owner.
10.MTC: Tirona does not have any reason to suspend
payment of rents. Ocampo is entitled to use and enjoy
the property and recover it from any person unlawfully
holding it.
11.Breton-Mendiola, who claimed to be the owner of the
land, filed a motion with leave to file intervention
before the RTC.
12.RTC: Issued a writ of execution pending appeal to
enforce MTC decision. Denied intervention of BretonMendiola.
13.CA: Until the partition of the estate of Alipio is ordered
pending the partition proceedings, Ocampo cannot
FACTS:
1. Petra Carpio vda. de Camilo had been in peaceful,
open, and adverse possession of a parcel of public
foreshore land in Zamboanga.
2. A commercial building was erected on the property.
3. Kee was a lessee of one of the apartments of said
commercial building.
4. Bannister filed an unlawful detainer case against de
Camilo and Kee.
5. The other petitioners, all surnamed Francisco, had also
been in possession of a parcel of public land adjoining
the land occupied by de Camilo. They erected a
commercial building therein.
6. The two commercial buildings were burned down.
7. 2 weeks after, Kee and Ong constructed a building of
their own. This was built in a portion previously
occupied by de Camilo and Francisco.
8. De Camilo filed a case for Forcible Entry against Kee
and Ong for the portion of her property encroached
upon before the Justice of Peace. The Franciscos filed a
similar case.
9. Ong/Kee: The land was leased to them by the
Municipality of Malangas.
10.Pending trial of the two cases, Ong and Kee filed a
complaint for Interpleader against de Camilo, Estrada,
Franciscos, Bannister, Mayor and Treasurer of
Malangas alleging that the filing of the cases for
forcible entry indicated that the defendants had
conflicting interest since they all claimed to be entitled
to the possession of the lot in question.
11.Ong and Kee alleged that they do not have interest on
the property other than as mere lessees.
12.De Camilo et. al instituted certiorari and mandamus
claiming that the Justice abused his discretion for
giving due course to the interpleader and it lacked
cause of action.
13.CFI: Justice had no jurisdiction to try the interpleader.
RATIO:
De Camilo et. al did not have conflicting claims against
Ong and Kee.
Their respective claim was separate and distinct from the
other.
o De Camilo wanted Ong and Kee to vacate the
portion of her property encroached upon by them.
o Same with Estrada and Franciscos.
They claimed possession of two different parcels of land,
of different areas, adjoining each other.
Ong and Kee HAVE interest in the subject matter. Their
interest was the prolongation of their occupancy of the
portions they encroached upon.
The requirements for a complaint of interpleader do NOT
exist.
The subject matter of the interpleader would come under
the original jurisdiction of the CFI, because it would not be
capable of pecuniary estimation, there having been no
showing that rentals were asked by the petitioners from
Ong and Kee.