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TRADERS ROYAL BANK v. IAC

This case has been cited 4 times or more.

2015-11-09
JARDELEZA, J.
Parenthetically the Cuaycong brothers, even before respondents could file the Original Complaint, had filed earlier on June 20, 1997, a case for Consignation and Damages[14] against respondents before the Regional Trial Court of Pasig Branch 69 ("RTC of Pasig"), docketed as Civil Case No. 66321. Cuaycong admitted that he was in possession of the funds owned by respondents in the total amount of Php 7,040,645.22[15] and offered to deposit the same with the court. In his defense, he alleged that he acted as fund manager for the respondents, who knew that he [Cuaycong] commingled their [respondents] funds with those of his other clients, including his brother Mark Angelo. Mark Angelo alleged that he had no direct dealings with the respondents.[16]
2015-11-09
JARDELEZA, J.
There is also identity of parties in both cases. Absolute identity of parties is not required, substantial identity of parties suffices. In P.L. Uy Realty Corporation v. ALS Management and Development Corporation,[72] we ruled that "there is substantial identity of parties when there is a community of interest between a party in the first case and a party in the second; and such identity of interest is sufficient to make them privy-in-law."[73] The principle of res judicata may not be evaded by the expedient of adding or eliminating some parties to the first and second action.[74] Accordingly, although not impleaded in Civil Case No. 66321, petitioners are "privy-in-law" to the compromise, because they are sued under a common cause of action with the Cuaycong brothers in Civil Case No. 02-1049.
2015-11-09
JARDELEZA, J.
Since res judicata applies, respondents cannot be permitted to further pursue a complaint for moral and exemplary damages and attorney's fees against petitioners. A judgment based on a compromise agreement is a judgment on the merits.[75] Hence, the compromise in Civil Case No. 66321 bars the continuation of Civil Case No. 02-1049.
2010-12-08
BRION, J.
In Traders Royal Bank v. Intermediate Appellate Court,[33] we declared that "property in the custody of the law cannot be interfered with without the custody of the proper court and properly legally attached is property in custodia legis."