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Valencia Vs CA

1. The petitioners leased a fishpond to private respondents but later rescinded the lease contract in a Bulacan court. The respondents then sued for damages in Manila court. 2. The main issue is whether the rescission case in Bulacan bars the damages case in Manila due to litis pendentia. The court rules no because the two cases do not meet all three requirements for litis pendentia: identical parties, identical rights/relief, and identical issues such that judgment in one case would result in res judicata in the other. 3. The relevant issue is whether a counterclaim was the proper response. The court also rules no, because a counterclaim is compulsory only

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Rean Raphaelle Gonzales
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47 views2 pages

Valencia Vs CA

1. The petitioners leased a fishpond to private respondents but later rescinded the lease contract in a Bulacan court. The respondents then sued for damages in Manila court. 2. The main issue is whether the rescission case in Bulacan bars the damages case in Manila due to litis pendentia. The court rules no because the two cases do not meet all three requirements for litis pendentia: identical parties, identical rights/relief, and identical issues such that judgment in one case would result in res judicata in the other. 3. The relevant issue is whether a counterclaim was the proper response. The court also rules no, because a counterclaim is compulsory only

Uploaded by

Rean Raphaelle Gonzales
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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1. Valencia vs.

Court of Appeals
FACTS: Petitioners leased a fishpond to private respondents but at some point achieved
the rescission of the lease contract in the Bulacan RTC. Trouble with execution of the
order eventually reach the IAC which directed respondents as owners of the fish, the
petitioners to respect the status quo. Petitioners violated the said order, prompting
respondents to sue for damages in the Manila RTC. Petitioner moved to dismiss the
Manila ruling on the ground of litis pendentia (since the Bulacan issue still subsisted) and
added that the proper remedy of the respondents was to file a compulsory counterclaim
in the same action for rescission.
MAIN ISSUE: Should the action for rescission of a lease contract against private
respondents be deemed to bar — on the ground of litis pendentia — an action for
damages brought by private respondent? – NO.
RELEVANT ISSUE: Is a compulsory counterclaim the proper vehicle for respondents’
claim of damages? – NO.
RULING ON MAIN ISSUE: This Court has consistently held, in a long line of cases, that the
requisites for the existence of litis pendentia as a ground for dismissal of an action are as
follows:
1) identity of parties, or at least such parties as represent the same interests in
both actions;
2) identity of rights asserted and relief prayed for, the relief being founded on the
same facts; and
3) the identity with respect to the two preceding particulars in the two cases is
such that any judgment that may be rendered in the pending case, regardless of
which party is successful, would amount to res adjudicata in the other case.
Only the first element exists. The relief sought in the Bulacan case (rescission) is not the
same as that in the Manila case (damages). Also, whether or not the rescission is
granted is foreign to the damages allegedly suffered by the respondents.
RULING ON RELEVANT ISSUE: The test by which to determine if a counterclaim is
compulsory is as follows:
1. Are the issues of fact and law raised by the claim and counterclaim largely the
same?
2. Would res judicata bar a subsequent suit on defendant's claim absent the
compulsory counterclaim rule?
3. Will substantially the same evidence support or refute plaintiff's claim as well
as defendant's counterclaim?
4. Is there any logical relation between the claim and the counterclaim?
The answer to all being negative, the counterclaim herein is merely permissive.

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