ANGELITO O. HAO, PETITIONER, VS. JENNIFER LAGAHID, ALSO KHOWN AS "JENNIFER LAGAHID-HAO."
- G.R. Number: G.R. No. 238095
- Promulgated: 2025-08-20
Doctrine
## Facts of the Case Samson Eng Guan Hao (Samson) was the registered owner of several properties and the brother of Angelito O. Hao (Angelito). Upon Samson's death, Jennifer Lagahid (Jennifer) executed an Affidavit of Self-Adjudication, claiming to be Samson's lawful wife and that her minor son, Ace Jefferson Lagahid Hao (Ace), was their child. She adjudicated Samson's properties to herself and Ace. Jennifer later executed two Affidavits of Loss for Samson's 15 Transfer Certificates of Title and, together with Ace, filed an Omnibus Petition for their replacement, which the trial court granted. Angelito subsequently filed a Petition for Relief from Judgment, asserting that the titles were not lost but were in his possession. He claimed Samson was never married and had no child, supporting this with certifications from statistical offices. The trial court granted Angelito's petition, declared the previous order void, and reinstated the original owner's duplicate copies. Angelito then filed criminal complaints for perjury against Jennifer and a separate civil complaint for damages based on her false and fraudulent claims. The Regional Trial Court (RTC) ruled in favor of Angelito, finding that Jennifer's misrepresentations violated Article 21 of the Civil Code and caused him annoyance, disturbance, and vexation. However, the Court of Appeals (CA) reversed the RTC's decision, holding that Angelito's complaint for damages was barred by *res judicata* and/or *litis pendentia*, arguing that claims arising from the petition for new titles should have been compulsory counterclaims and that claims arising from criminal cases were deemed instituted with the criminal actions. ## Issues 1. Whether Angelito's separate civil action for damages arising from Jennifer's independent civil liability is barred by *res judicata* or *litis pendentia*. 2. Whether Angelito's claim for damages arising from the grant of the Petition for Relief from Judgment could have been set up as a compulsory counterclaim. ## Decision / Rationale **Issue 1:** The Court ruled that Angelito may pursue a separate civil action for damages arising from Jennifer's independent civil liability. The Court distinguished between civil liability ex delicto (arising from a crime) and independent civil liabilities. While civil liability ex delicto is deemed instituted with the criminal action unless waived, reserved, or instituted prior to the criminal action, **Article 33 of the Civil Code** allows for independent civil actions in cases of defamation, fraud, and physical injuries, which proceed independently of the criminal prosecution. "Fraud" in Article 33 is to be understood in its generic sense, encompassing acts calculated to deceive. Angelito's complaint for damages stemmed from Jennifer's fraudulent acts, specifically her misrepresentations to gain control of Samson's titles, which constitutes fraud under Article 33. The failure to reserve the right to file a separate civil action in the criminal case does not waive the right to file an independent civil action under Article 33. **Issue 2:** The Court ruled that Angelito's claim for damages arising from the grant of the Petition for Relief from Judgment could not have been set up as a compulsory counterclaim. A compulsory counterclaim is a claim against an opposing party, and it presupposes the existence of a claim against the party filing the counterclaim. In Jennifer's Omnibus Petition for the issuance of new owner's duplicate certificates of title, there was no defendant, and its objective was merely to determine if the titles were lost and if the petitioner had sufficient interest. Angelito was not a party to this petition and was not aware of its existence, thus he could not have interposed a compulsory counterclaim. Furthermore, the court in the proceedings for the issuance of new owner's duplicate titles loses jurisdiction when it is found that the subject titles were not actually lost or destroyed. In such a…
Keywords
Article 1191 Civil Code, RA 9262 Section 5, Rule 45 Rules of Court, Article 21 Civil Code, Article 33 Civil Code, Article 32 Civil Code, Article 34 Civil Code, Article 2176 Civil Code, Article 100 Revised Penal Code, Rule 111 Rules of Court Section 1, Rule 110 Rules of Court Section 1, Rule 111 Rules of Court Section 3, Rule 38 Section 6 Rules of Court, Presidential Decree No. 1529 Section 109, Rule 17 Section 3 2019 Rules of Civil Procedure, Doctrine of Piercing the Corporate Veil, Fruit of the Poisonous Tree, Res Judicata, Litis Pendentia, Independent Civil Action