Bliss vs. Diaz

6. April 1992: BDC executed a Contract to Sell in favor of Diaz.
However,
on April 1994, BDC informed Diaz that an Edgar Arreza was claiming
Full Case Title: Bliss Development Corp / Home Guaranty Corporation vs.
Montano Diaz, Domingo Tapay, and Edgar H. Arreza that the heirs of Sps. Melgazo sold to him the rights over the property.
a. BDC placed Diaz’ account in “inactive status”
Date of Promulgation: August 5, 2015 7. To resolve the confliccting claims of Arreza and Diaz, BDC filed a
complaint for interpleader against them, before the Makati RTC.
Doctrine: For purposes of the requirements of res judicata, in an
interpleader case, the opposing parties are those that are impleaded, and
First RTC ruling: That the signatures of Sps. Melgazo signing over their rights to
not the person who initiated the interpleader.
Nacua were forgeries. Therefore, Arreza had a better right over the property.
More generally, there is no identity of parties nor identity of subject matter This decision became final and executory.
between an interpleader case and a non-interpleader case.
8. August 1996: Diaz files a complaint for sum of money against BDC
Recit - Ready Summary: before the RTC Makati.
a. Diaz argued that BDC and Tapay’s representations led him to
Facts: believe that he had a good title over the property, but due to
1. Petitioner Bliss (eventually reorganized as Home Guaranty Corp) is a the court’s ruling in the interpleader case, he was constrained
registered owner of a piece of land in Diliman, Quezon City. to transfer the property to Arreza.
2. October 1984: Executes a deed of sale over the property in favor of b. Asked for BDC and Arreza to pay him 1.1m pesos, representing
Sps. Melgazo, both of whom are now deceased the amount he paid to assume Tapay’s rights;
3. May 1991: A Rodolfo Nacua sends a letter to BDC, alleging that the i. Tapay to pay him 600k for the amount he paid Tapay;
Melgazos had transferred to him the rights over the Diliman property. ii. BDC and Tapay to pay him 500k as moral damages
a. He expressed willingness to pay the outstanding obligation of iii. Among other damages.
the Sps. Melgazo to the BDC. c. BDC and Tapay argued their acts to be lawful and in good
4. However, before the property could be fully paid for, Nacua sold his faith.
rights to an Olivia Garcia through a Deed of Transfer of Rights. d. Arreza filed MtD, citing res judicata, arguing that Diaz’ claim is
a. Garcia transferred to Elizabeth Reyes; a compulsory one that should have been argued in the
b. Reyes transferred to Domingo Tapay; Interpleader case.
c. Tapay sold his rights to respondent Montano Diaz for 600k. i. RTC denied MtD
5. Diaz paid BDC the amortizations due (406k) and BDC issued a permit ii. CA on certiorari, affirmed.
to occupy the property to Diaz. Diaz introduced improvements iii. Supreme Court ruled that claim against Arreza is
amounting to 700k. barred by res judicata, that the claim is a compulsory
one. Case was dismissed.
Second RTC Ruling: Found that Diaz failed to prove his being an assignee in matter and cause of action: not only as to matters decided in the first
good faith, dismissed the complaint for lack of merit. action, but also as to every other matter which could have been set up
in the prior action.
Diaz appeals to the CA.
In the case, the Court found that the essential elements of res judicata were
CA ruling: reversed the RTC and instead ruled that Diaz is entitled to be paid not present.
reimbursement and damages. CA ruled that Diaz is both a buyer and builder in
good faith. First, the interpleader case was between Arreza and Diaz. While it was the BDC
- They said that Diaz need not go beyond the title to be considered a that initiated the interpleader, the opposing parties were in fact Arreza and
buyer in good faith, because it is registered land. Diaz.
- BDC and Tapay were ordered to pay.
Second, the issues in the interpleader revolved around the conflicting claims of
MRs denied: Arreza and Diaz, and not their claims against BDC.
- BDC argued that the Interpleader case served to the effect that Diaz
cannot be declared a buyer in good faith; and Therefore, no identity of parties nor subject matter, if the interpleader case
- Tapay moved for MR arguing he was not aware fo the defect in the and the one under discussion are compared.
title sold.
Hence, the issue before the Court. Other issues:
1. BDC acted in bad faith (they knew about Arreza’s claim as early as
Issue/s: (For purposes of the discussion in Civpro) 1991, and even accepted payments)
- WON the claim by respondent is barred, in light of the doctrine of 2. Diaz is not a purchaser for value and in good faith (element of
immutability of judgment in the interpleader case. (No) purchaser buying property without notice that other persons have a
right or interest in such property is lacking)
Ratio/ Legal Basis: 3. BDC is liable to return the amortizations paid by Diaz, pursuant to the
The present claim is not barred by the interpleader case. doctrine of unjust entrichment
4. Both parties are in bad faith, and therefore both shall be treated as
In the complaint for sum of money, The Court ruled that the claim against though they are in good faith (Art. 453)
Arreza is barred by res judicata because of the ruling in the Interpleader case. Disposition:
- The Court reiterated that the claim for reimbursement should have WHEREFORE, in view of the foregoing, the January 21, 2014 Decision of the
been alleged and proved in the prior case, and failure to do so bars Court of Appeals in CA-G.R. CV No. 99179 is hereby MODIFIED to read as
action on such claims. follows: (1) petitioner Bliss Development Corporation/Home Guaranty
- Specifically, the Court said that prior judgment is conclusive in a Corporation is ordered topay respondent Montano M. Diaz the amount of
subsequent suit between the same parties with the same subject P1,106,915.58 for the amortizations paid and the amount spent on
improvements on the property; and (2) Domingo Tapay is ordered to pay
respondent Montano M. Diaz the amount of P600,000.00, the amount he paid
for the transfer of rights.
Cases cited:
Laws cited:

Bliss vs. Diaz

Uploaded by

Copyright:

Available Formats

Bliss vs. Diaz

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Bliss vs. Diaz

Uploaded by

Copyright:

Available Formats

6. April 1992: BDC executed a Contract to Sell in favor of Diaz.

You might also like