Felipe Juan v. Go Cotay

Summary

This 1913 Supreme Court case established important precedent on res adjudicata in contractual disputes. Plaintiffs purchased palay for P398.75 but defendants failed to deliver. After losing their first action on appeal (despite initial victory), plaintiffs filed a second action seeking rescission and damages. The Supreme Court held that res adjudicata barred the second action since both cases involved identical parties, subject matter, and causes of action. The Court emphasized that under Article 1124 of the Civil Code, a contracting party may choose between specific performance or rescission with damages, and the first action's alternative prayer covered both remedies. This decision reinforced the finality of judgments and the principle that litigation must have an end, establishing that contractual remedy elections in pleadings can encompass multiple forms of relief under res adjudicata doctrine.