You're currently signed in as:
User

VICTORIO ESPERAS v. CA

This case has been cited 7 times or more.

2015-06-17
BRION, J.
We held in Esperas v. The Court of Appeals[11] that the ultimate test in determining the presence of identity of cause of action is to consider whether the same evidence would support the cause of action in both the first and the second cases. Under the same evidence test, when the same evidence support and establish both the present and the former causes of action, there is likely an identity of causes of action.[12]
2007-06-26
GARCIA, J.
On the matter of identity of causes of action, the Court holds that there is such identity between TBP Case No. 87-02388 and the instant case, which is the grant of the alleged behest loan. For perspective, however, a slightly different reasons are given in both cases for characterizing the subject loan as behest. The alleged "special treatment" given to PAFICO and the "questionable viability" of its soy beans processing projects are the reasons given in the first case, whereas reference to "under collateralization" and "under capitalization" is mentioned in the present case. But then, the application of the res judicata doctrine cannot be evaded by merely varying the form of the action or engaging a different method of presenting the issue.[48] Legal theories do not operate to constitute a cause of action; new legal theories do not amount to a new cause of action so as to defeat the application of the principle of res judicata.[49]
2007-06-08
QUISUMBING, J.
In several cases, we said that the ultimate test to ascertain identity of action is whether or not the same evidence fully supports and establishes both the present cause of action and the former cause of action.[22] Causes of action are identical when there is an identity in the facts essential to the maintenance of the two actions, or where the same evidence will sustain both actions. If the same facts or evidence can sustain either, the two actions are considered the same, so that the judgment in one is a bar to the other. [23] Here, we hold there is, patently, identity of causes of action.
2005-07-22
CALLEJO, SR., J.
The ultimate test to ascertain identity of causes of action is whether or not the same evidence fully supports and establishes both the first and second cases. The application of the doctrine of res judicata cannot be excused by merely varying the form of the action or engaging a different method of presenting the issue.[38]
2001-10-23
QUISUMBING, J.
We are not persuaded by the latter argument.  The four elements of res judicata are: (1) the judgment sought to bar the new action must be final; (2) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be between the first and second action, identity of parties, subject matter and causes of action.[10] The parties do not dispute the existence of the first three conditions. It is the fourth condition which private respondent claims as non-existent, i.e., there's no identity of causes of action.
2001-05-09
PANGANIBAN, J.
For the doctrine to apply, four requisites must be met:  (1) the former judgment or order must be final; (2) it must be a judgment or an order 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 actions, identity of parties, of subject matter and of cause of action.[20]