Albert Nabus v. The Honorable Court of Appeals

Summary

This case involves a land sale dispute where Nabus sold property to Lim in 1965 for P258,000 in installments. When Lim allegedly failed to pay the final P75,000, Nabus first filed for reconveyance under the Public Land Act, which was dismissed for failure to deposit the repurchase price. He then filed for contract rescission under the Civil Code. The Supreme Court ruled that while res judicata did not apply due to different causes of action requiring different evidence, the rescission action had prescribed. The Court distinguished between actions for repurchase under public land laws versus rescission under civil law, emphasizing that different legal theories constitute separate causes of action even when arising from the same contract.