This case has been cited 5 times or more.
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2013-11-25 |
DEL CASTILLO, J. |
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| The contention is specious. "Res judicata means 'a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment.'"[46] For res judicata to apply there must among others be, between the first and the second actions, identity of the parties, identity of subject matter, and identity of causes of action.[47] Here, there is no identity of parties between Civil Case No. 3514 and the instant case. "Identity of parties exists 'where the parties in both actions are the same, or there is privity between them, or they are successors-in-interest by title subsequent to the commencement of the action, litigating for the same thing and under the same title and in the same capacity.'"[48] In Civil Case No. 3514, the action was directed against Benjamin E. Martinez, Jr. and Francisco P. Martinez in their capacities as Mayor and Chief of the Permit and License Division of the Municipality of Balayan, Batangas, respectively. On the other hand, respondent, in the instant case, is being sued in his capacity as Provincial Treasurer of the Province of Batangas. While the defendants in both cases similarly sought to enforce the tax obligation of petitioner, they were sued under different capacities. Moreover, there is no identity in the causes of action between the two cases. In Civil Case No. 3514, the propriety of the municipal officials' closure/stoppage of petitioner's business operation in Balayan, Batangas was the one in question while what is involved in this case is respondent's act of issuing Warrants of Levy and proceeding with the auction sale of the real properties of petitioner. Clearly, the principle of res judicata does not apply. The RTC and the CA are therefore correct in ruling that respondent, not being a party thereto, is not bound by the Decision rendered in Civil Case No. 3514. | |||||
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2012-09-17 |
DEL CASTILLO, J. |
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| The Decision of this Court in G.R. Nos. 159460 and 159461, therefore, constitutes res judicata to the present consolidated cases. "Res judicata means 'a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment.'"[111] It denotes "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."[112] For res judicata, in its concept as a bar by former judgment to apply, the following must be present: The former judgment or order is final; | |||||
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2011-02-14 |
ABAD, J. |
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| Here, the fraud that Solid Homes proposed as ground for its petition for relief is Investco and AFPMBAI's alleged prior knowledge of the sale of the disputed lands to Solid Homes, which fraud goes into the merit of the case rather than on Solid Homes' right to be heard on its action. In effect the RTC will rehear the issue of whether or not AFPMBAI was a buyer in good faith, an issue barred by res judicata since the Court has already decided the same with finality in the latter's favor on March 3, 2000 in G.R. 104769 and G.R. 135016, AFPMBAI v. CA. The principle of res judicata holds that issues actually and directly resolved in a former suit cannot be raised in any future case between the same parties.[26] | |||||
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2010-07-05 |
NACHURA, J. |
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| Res judicata means "a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment." It lays the rule that an existing final judgment or decree rendered on the merits, without fraud or collusion, by a court of competent jurisdiction, upon any matter within its jurisdiction, is conclusive of the rights of the parties or their privies, in all other actions or suits in the same or any other judicial tribunal of concurrent jurisdiction on the points and matters in issue in the first suit.[51] | |||||
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2008-09-22 |
CARPIO, J. |
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| (a) In case of a judgment or a final order against a specific thing, or in respect to the probate of a will, or the administration of the estate of a deceased person, or in respect to the personal, political, or legal condition or status of a particular person or his relationship to another, the judgment or final order is conclusive upon the title to the thing, the will or administration, or the condition, status or relationship of the person; however, the probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate; x x x (Emphasis supplied) Res judicata or bar by prior judgment means that when a right or fact had already been judicially tried on the merits and determined by a court of competent jurisdiction, the final judgment or order shall be conclusive upon the parties and those in privity with them and constitutes an absolute bar to subsequent actions involving the same claim, demand or cause of action.[12] Res judicata promotes the public policy and sound practice that stability should be accorded to final judgments and orders; otherwise, there will be no end to litigation.[13] Thus, even at the risk of occasional errors, judgments of courts should become final at some definite time fixed by law and that parties should not be allowed to litigate the same issues over again.[14] | |||||