Lawyerly

GR No. 163598

2015-08-12

AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. FIL-ESTATE INC.

JARDELEZA, J.

Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[41]

GR No. 204641

2015-06-29

CAMARINES SUR IV ELECTRIC COOPERATIVE v. EXPEDITA L. AQUINO

MENDOZA, J.

A case is barred by prior judgment or res judicata when the following requisites concur: (1) the former judgment is, final; (2) it is rendered by a court having jurisdiction over the subject matter and the parties; (3) it is a judgment; or an order on the merits; (4) there is — between the first and the second actions — identity of parties, of subject matter, and of causes of action.[28]

GR No. 173783

2015-06-17

RIVIERA GOLF CLUB v. CCA HOLDINGS

BRION, J.

Res judicata requires the concurrence of the following requisites: (1) the former judgment must be final; (2) it must have been rendered by a court having jurisdiction of the subject matter and the parties; (3) it must be a judgment on the merits; and (4) there must be, between the first and second actions (a) identity of parties, (b) identity of subject matter, and (c) identity of causes of action.[6]

GR No. 212277

2015-02-11

ROBERT v. GILBERT

PERLAS-BERNABE, J.

By resolving the substantive issue therein that is, the right of Gilbert to recover the de facto possession of the subject property arising from Robert's breach of the undated lease contract the MCTC-Nabunturan-Mawab's January 24, 2006 Decision should be properly considered as a judgment on the merits. In Allied Banking Corporation v. CA,[40] citing Escarte v. Office of the President,[41] the Court defined "judgment on the merits" as follows: As a technical legal term, 'merits' has been defined in law dictionaries as a matter of substance in law, as distinguished from matter of form, and as the real or substantial grounds of action or defense, in contradistinction to some technical or collateral matter raised in the course of the suit. A judgment is upon the merits when it amounts to a declaration of the law to the respective rights and duties of the parties, based upon the ultimate fact or state of facts disclosed by the pleadings and evidence, and upon which the right of recovery depends, irrespective of formal, technical or dilatory objectives or contentions.

GR No. 186622

2014-01-22

PEBLIA ALFARO v. SPS. EDITHO AND HERA DUMALAGAN

PEREZ, J.

Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[15] The elements of res judicata are as follows: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and the second action, identity of parties, of subject matter and cause of action.[16]

GR No. 159691

2013-06-13

HEIRS OF MARCELO SOTTO v. MATILDE S. PALICTE

BERSAMIN, J.

The doctrine of res judicata is an old axiom of law, dictated by wisdom and sanctified by age, and founded on the broad principle that it is to the interest of the public that there should be an end to litigation by the same parties over a subject once fully and fairly adjudicated. It has been appropriately said that the doctrine is a rule pervading every well-regulated system of jurisprudence, and is put upon two grounds embodied in various maxims of the common law: one, public policy and necessity, which makes it to the interest of the State that there should be an end to litigation interest reipublicae ut sit finis litium; the other, the hardship on the individual that he should be vexed twice for one and the same cause nemo debet bis vexari pro una et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquillity and happiness.[19] The doctrine is to be applied with rigidity because:x x x the maintenance of public order, the repose of society, and the quiet of families require that what has been definitely determined by competent tribunals shall be accepted as irrefragable legal truth. So deeply is this principle implanted in xxx jurisprudence that commentators upon it have said, the res judicata renders white that which is black and straight that which is crooked. Facit excurvo rectum, ex albo nigrum. No other evidence can afford strength to the presumption of truth it creates, and no argument can detract from its legal efficacy.[20]

GR No. 181962

2012-01-16

CEFERINO S. CABREZA v. AMPARO ROBLES CABREZA

SERENO, J.

As to the last requisite, a final judgment on the merits by a court that has jurisdiction over the parties and over the subject matter in the Petition to nullify the Writ of Possession would have barred subsequent judgment on the Complaint for Declaration of Nullity of the Deed of Sale based on the principle of res judicata.[11]

GR No. 156185

2011-09-12

CATALINA B. CHU v. SPS. FERNANDO C. CUNANAN

BERSAMIN, J.

Res judicata means a matter adjudged, a thing judicially acted upon or decided; a thing or matter settled by judgment.[29] The doctrine of res judicata is an old axiom of law, dictated by wisdom and sanctified by age, and founded on the broad principle that it is to the interest of the public that there should be an end to litigation by the same parties over a subject once fully and fairly adjudicated. It has been appropriately said that the doctrine is a rule pervading every well-regulated system of jurisprudence, and is put upon two grounds embodied in various maxims of the common law: the one, public policy and necessity, which makes it to the interest of the State that there should be an end to litigation -interest reipublicae ut sit finis litium; the other, the hardship on the individual that he should be vexed twice for one and the same cause - nemo debet bis vexari pro una et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquillity and happiness.[30]

GR NO. 159876

2007-06-26

DINO A. CRUCILLO v. OFFICE OF OMBUDSMAN

GARCIA, J.

Res judicata, according to Black, "refers to the rule that a final judgment rendered by a court of competent jurisdiction on the merits is conclusive as to the rights of the parties and their privies and, as to them, constitutes an absolute bar to a subsequent action involving the same demand or cause of action."[41] Res judicata is, in fine, a rule of preclusion to the end that facts or issues settled by final judgment should not be tried anew.[42] It has two aspects: 1) the effect of a judgment as a bar to the prosecution of a second action upon the same claim, demand or cause of action; this is designated as "bar by former judgment"; and 2) precludes the relitigation of a particular fact or issues in another action between the same parties on a different claim or cause of action. This is the rule on "conclusiveness of judgment."[43]

GR No. 157616

2005-07-22

ISIDRO PEREZ v. CA

CALLEJO, SR., J.

(a) finality of the former judgment; (b) the court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be, between the first and second actions, identity of parties, subject matter and causes of action.[31] A judgment or order is on the merits of the case when it determines the rights and liabilities of the parties based on the ultimate facts as disclosed by the pleadings or issues presented for trial. It is not necessary that a trial, actual hearing or argument on the facts of the case ensued. For as long as the parties had the full legal opportunity to be heard on their respective claims and contentions, the judgment or order is on the merits.[32] An order of the trial court on the ground that the complaint does not state a cause of action is a determination of the case on its merits.[33] Such order whether right or wrong bars another action based upon the same cause of action.[34] The operation of the order as res judicata is not affected by a mere right of appeal where the appeal has not been taken or by an appeal which never has been perfected.[35]

GR NO. 153514

2005-06-08

SPS. LAZARO M. ZULUETA AND PERLA SUCAYAN-ZULUETA v. JOSE WONG

CALLEJO, SR., J.

An order is one on the merits of the case if based on legal rights, as distinguished from mere matters of practice, procedure, jurisdiction or form.[22] It has been held that an order is upon the merits when it amounts to a declaration of the law to the respective rights and duties of the parties, based upon the ultimate facts or state of facts disclosed by the pleadings and evidence, and upon which the right of recovery depends, irrespective of formal, technical or dilatory objections or contentions.[23] A dismissal of a complaint on the ground that it does not state a cause of action does not make the dismissal any less an adjudication on the merits.[24]

	GR No. 163598 2015-08-12	AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. FIL-ESTATE INC. JARDELEZA, J.
Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[41]
	GR No. 204641 2015-06-29	CAMARINES SUR IV ELECTRIC COOPERATIVE v. EXPEDITA L. AQUINO MENDOZA, J.
A case is barred by prior judgment or res judicata when the following requisites concur: (1) the former judgment is, final; (2) it is rendered by a court having jurisdiction over the subject matter and the parties; (3) it is a judgment; or an order on the merits; (4) there is — between the first and the second actions — identity of parties, of subject matter, and of causes of action.[28]
	GR No. 173783 2015-06-17	RIVIERA GOLF CLUB v. CCA HOLDINGS BRION, J.
Res judicata requires the concurrence of the following requisites: (1) the former judgment must be final; (2) it must have been rendered by a court having jurisdiction of the subject matter and the parties; (3) it must be a judgment on the merits; and (4) there must be, between the first and second actions (a) identity of parties, (b) identity of subject matter, and (c) identity of causes of action.[6]
	GR No. 212277 2015-02-11	ROBERT v. GILBERT PERLAS-BERNABE, J.
By resolving the substantive issue therein that is, the right of Gilbert to recover the de facto possession of the subject property arising from Robert's breach of the undated lease contract the MCTC-Nabunturan-Mawab's January 24, 2006 Decision should be properly considered as a judgment on the merits. In Allied Banking Corporation v. CA,[40] citing Escarte v. Office of the President,[41] the Court defined "judgment on the merits" as follows: As a technical legal term, 'merits' has been defined in law dictionaries as a matter of substance in law, as distinguished from matter of form, and as the real or substantial grounds of action or defense, in contradistinction to some technical or collateral matter raised in the course of the suit. A judgment is upon the merits when it amounts to a declaration of the law to the respective rights and duties of the parties, based upon the ultimate fact or state of facts disclosed by the pleadings and evidence, and upon which the right of recovery depends, irrespective of formal, technical or dilatory objectives or contentions.
	GR No. 186622 2014-01-22	PEBLIA ALFARO v. SPS. EDITHO AND HERA DUMALAGAN PEREZ, J.
Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[15] The elements of res judicata are as follows: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and the second action, identity of parties, of subject matter and cause of action.[16]
	GR No. 159691 2013-06-13	HEIRS OF MARCELO SOTTO v. MATILDE S. PALICTE BERSAMIN, J.
The doctrine of res judicata is an old axiom of law, dictated by wisdom and sanctified by age, and founded on the broad principle that it is to the interest of the public that there should be an end to litigation by the same parties over a subject once fully and fairly adjudicated. It has been appropriately said that the doctrine is a rule pervading every well-regulated system of jurisprudence, and is put upon two grounds embodied in various maxims of the common law: one, public policy and necessity, which makes it to the interest of the State that there should be an end to litigation interest reipublicae ut sit finis litium; the other, the hardship on the individual that he should be vexed twice for one and the same cause nemo debet bis vexari pro una et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquillity and happiness.[19] The doctrine is to be applied with rigidity because:x x x the maintenance of public order, the repose of society, and the quiet of families require that what has been definitely determined by competent tribunals shall be accepted as irrefragable legal truth. So deeply is this principle implanted in xxx jurisprudence that commentators upon it have said, the res judicata renders white that which is black and straight that which is crooked. Facit excurvo rectum, ex albo nigrum. No other evidence can afford strength to the presumption of truth it creates, and no argument can detract from its legal efficacy.[20]
	GR No. 181962 2012-01-16	CEFERINO S. CABREZA v. AMPARO ROBLES CABREZA SERENO, J.
As to the last requisite, a final judgment on the merits by a court that has jurisdiction over the parties and over the subject matter in the Petition to nullify the Writ of Possession would have barred subsequent judgment on the Complaint for Declaration of Nullity of the Deed of Sale based on the principle of res judicata.[11]
	GR No. 156185 2011-09-12	CATALINA B. CHU v. SPS. FERNANDO C. CUNANAN BERSAMIN, J.
Res judicata means a matter adjudged, a thing judicially acted upon or decided; a thing or matter settled by judgment.[29] The doctrine of res judicata is an old axiom of law, dictated by wisdom and sanctified by age, and founded on the broad principle that it is to the interest of the public that there should be an end to litigation by the same parties over a subject once fully and fairly adjudicated. It has been appropriately said that the doctrine is a rule pervading every well-regulated system of jurisprudence, and is put upon two grounds embodied in various maxims of the common law: the one, public policy and necessity, which makes it to the interest of the State that there should be an end to litigation -interest reipublicae ut sit finis litium; the other, the hardship on the individual that he should be vexed twice for one and the same cause - nemo debet bis vexari pro una et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquillity and happiness.[30]
	GR NO. 159876 2007-06-26	DINO A. CRUCILLO v. OFFICE OF OMBUDSMAN GARCIA, J.
Res judicata, according to Black, "refers to the rule that a final judgment rendered by a court of competent jurisdiction on the merits is conclusive as to the rights of the parties and their privies and, as to them, constitutes an absolute bar to a subsequent action involving the same demand or cause of action."[41] Res judicata is, in fine, a rule of preclusion to the end that facts or issues settled by final judgment should not be tried anew.[42] It has two aspects: 1) the effect of a judgment as a bar to the prosecution of a second action upon the same claim, demand or cause of action; this is designated as "bar by former judgment"; and 2) precludes the relitigation of a particular fact or issues in another action between the same parties on a different claim or cause of action. This is the rule on "conclusiveness of judgment."[43]
	GR No. 157616 2005-07-22	ISIDRO PEREZ v. CA CALLEJO, SR., J.
(a) finality of the former judgment; (b) the court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be, between the first and second actions, identity of parties, subject matter and causes of action.[31] A judgment or order is on the merits of the case when it determines the rights and liabilities of the parties based on the ultimate facts as disclosed by the pleadings or issues presented for trial. It is not necessary that a trial, actual hearing or argument on the facts of the case ensued. For as long as the parties had the full legal opportunity to be heard on their respective claims and contentions, the judgment or order is on the merits.[32] An order of the trial court on the ground that the complaint does not state a cause of action is a determination of the case on its merits.[33] Such order whether right or wrong bars another action based upon the same cause of action.[34] The operation of the order as res judicata is not affected by a mere right of appeal where the appeal has not been taken or by an appeal which never has been perfected.[35]
	GR NO. 153514 2005-06-08	SPS. LAZARO M. ZULUETA AND PERLA SUCAYAN-ZULUETA v. JOSE WONG CALLEJO, SR., J.
An order is one on the merits of the case if based on legal rights, as distinguished from mere matters of practice, procedure, jurisdiction or form.[22] It has been held that an order is upon the merits when it amounts to a declaration of the law to the respective rights and duties of the parties, based upon the ultimate facts or state of facts disclosed by the pleadings and evidence, and upon which the right of recovery depends, irrespective of formal, technical or dilatory objections or contentions.[23] A dismissal of a complaint on the ground that it does not state a cause of action does not make the dismissal any less an adjudication on the merits.[24]

ALLIED BANKING CORPORATION v. CA