Lawyerly

GR No. 213197

2015-10-21

REMEGIO A. CHING v. SAN PEDRO COLLEGE OF BUSINESS ADMINISTRATION

MENDOZA, J.

Res judicata is commonly understood as a bar to the prosecution of a second action upon the same claim, demand or cause of action. In traditional terminology, this is known as merger or bar; in modern terminology, it is called claim preclusion.[30] In jurisprudence, it is referred to as bar by former judgment. It requires that a former judgment or order must be final; that the judgment or order must be on the merits; that it must have been rendered by a court having jurisdiction over the subject matter and the parties; and that there must be, between the first and the second action, identity of parties, of subject matter and cause of action.[31]

GR No. 171582

2015-08-19

ALBERTO T. LASALA v. NATIONAL FOOD AUTHORITY

BRION, J.

Its elements are the following: (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.[31] There is res judicata when all these requisites concur.

GR No. 190983

2015-07-29

SURENDRA GOBINDRAM DASWANI v. BANCO DE ORO UNIVERSAL BANK

BRION, J.

Res judicata exists, if the following requisites are all present: "(1) the former judgment or order had already been final; (2) the judgment or order had been on the merits; (3) it had been rendered by a court having jurisdiction over the subject matter and the parties; (4) and because of the concurrence of the first three requisites, there is now between the first and the second action, identity of parties, of subject matter and cause of action."[23]

GR No. 195443

2014-09-17

JUANARIO G. CAMPIT v. ISIDRA B. GRIPA

BRION, J.

A matter adjudged with finality by a competent court having jurisdiction over the parties and the subject matter already constitutes res judicata in another action involving the same cause of action, parties and subject matter. The doctrine of res judicata provides that a final judgment on the merits rendered by a court of competent jurisdiction, is conclusive as to the rights of the parties and their privies and constitutes as an absolute bar to subsequent actions involving the same claim, demand, or cause of action.[12] Thus, the validity of petitioner's title, having been settled with finality in Civil Case No. 15357, could no longer be reviewed in the present case.

GR No. 182153

2014-04-07

TUNG HO STEEL ENTERPRISES CORPORATION v. TING GUAN TRADING CORPORATION

BRION, J.

Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive on the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[19] For res judicata to apply, the final judgment must be on the merits of the case which means that the court has unequivocally determined the parties' rights and obligations with respect to the causes of action and the subject matter of the case.[20]

GR No. 159691

2013-06-13

HEIRS OF MARCELO SOTTO v. MATILDE S. PALICTE

BERSAMIN, J.

In all the five cases (Civil Case No. CEB-24293 included), a n identity of parties existed because the parties were the same, or there was privity among them, or some of the parties were successors-in-interest litigating for the same thing and under the same title and in the same capacity.[15] An absolute identity of the parties was not necessary, because a shared identity of interest sufficed for res judicata to apply.[16] Moreover, mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, would be sufficient.[17] As such, the fact that a previous case was filed in the name of the Estate of Sotto only was of no consequence.

GR No. 156185

2011-09-12

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

BERSAMIN, J.

There is identity of parties when 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.[35] The requirement of the identity of parties was fully met, because the Chus, on the one hand, and the Cunanans, on the other hand, were the parties in both cases along with their respective privies. The fact that the Carloses and Benelda Estate, defendants in Civil Case No. 12251, were not parties in the compromise agreement was inconsequential, for they were also the privies of the Cunanans as transferees and successors-in-interest. It is settled that the absolute identity of parties was not a condition sine qua non for res judicata to apply, because a shared identity of interest sufficed.[36] Mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, was sufficient.[37]

GR No. 165697

2009-08-04

ANTONIO NAVARRO v. METROPOLITAN BANK

PERALTA, J.

The principle of res judicata 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 their former suit.[40] It obtains where a court of competent jurisdiction has rendered a final judgment or order on the merits of the case, which operates as an absolute bar against a subsequent action for the same cause.[41] A substantial identity is necessary to warrant the application of the rule, and the addition or elimination of some parties or the difference in form and nature of the two actions would not alter the situation.[42] In other words, when material facts or questions in issue in a former action were conclusively settled by a judgment rendered therein, such facts or questions constitute res judicata and may not be again litigated in a subsequent action between the same parties or their privies regardless of the form of the latter.[43]

GR No. 163360

2007-06-08

HEIRS OF IGMEDIO* MAGLAQUE v. CA

QUISUMBING, J.

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.[13]

GR NO. 148408

2006-07-14

CONCEPCION PARAYNO v. JOSE JOVELLANOS

CORONA, 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.[21] For res judicata to apply, the following elements must be present: (1) the judgment or order must be final; (2) the judgment 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 second actions, identity of parties, of subject matter and of cause of action.[22]

GR NO. 157557

2006-03-10

REPUBLIC v. RAMON YU

The doctrine of res judicata provides that a final judgment on the merits rendered by a court of competent jurisdiction, is conclusive as to the rights of the parties and their privies and constitutes an absolute bar to subsequent actions involving the same claim, demand, or cause of action. [20] Considering that the sale on which respondents based their right to reversion has long been nullified, they have not an iota of right over the property and thus, have no legal personality to bring forth the action for reversion of expropriated property. Lack of legal personality to sue means that the respondents are not the real parties-in-interest. This is a ground for the dismissal of the case, related to the ground that the complaint evidently states no cause of action. [21]

GR No. 162788

2005-07-28

SPS. JULITA DE LA CRUZ AND FELIPE DE LA CRUZ v. PEDRO JOAQUIN

PANGANIBAN, J.

Under res judicata, 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 and on all points and matters determined in the previous suit.[43] The term literally means a "matter adjudged, judicially acted upon, or settled by judgment."[44] The principle bars a subsequent suit involving the same parties, subject matter, and cause of action. Public policy requires that controversies must be settled with finality at a given point in time.

GR NO. 137694

2005-01-17

DEVELOPMENT BANK OF PHILIPPINES v. LA CAMPANA DEVELOPMENT CORPORATION

CHICO-NAZARIO, 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.[27]

GR No. 135365

2004-08-31

ROSARIO BARBACINA v. CA

AUSTRIA-MARTINEZ, J.

The supposed differences are, however, deceptive. Note that the inclusion of the Gavino spouses as defendants in the present case is merely due to the fact that they are successors-in-interest of Cirilo Farinas. In Civil Case No. Q-28101, Rosario Farinas, the sister of Cirilo Farinas, was included because petitioner alleged therein that Rosario Farinas was actually the one interested in the subject lot, but since she had already been awarded one lot, she used the name of Cirilo Farinas to apply for the award of the subject lot. Clearly, the Gavino spouses and Rosario Farinas represent one and the same interest - that of Cirilo Farinas'. In Taganas vs. Emuslan,[7] it was held that:There is identity of parties 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.

	GR No. 213197 2015-10-21	REMEGIO A. CHING v. SAN PEDRO COLLEGE OF BUSINESS ADMINISTRATION MENDOZA, J.
Res judicata is commonly understood as a bar to the prosecution of a second action upon the same claim, demand or cause of action. In traditional terminology, this is known as merger or bar; in modern terminology, it is called claim preclusion.[30] In jurisprudence, it is referred to as bar by former judgment. It requires that a former judgment or order must be final; that the judgment or order must be on the merits; that it must have been rendered by a court having jurisdiction over the subject matter and the parties; and that there must be, between the first and the second action, identity of parties, of subject matter and cause of action.[31]
	GR No. 171582 2015-08-19	ALBERTO T. LASALA v. NATIONAL FOOD AUTHORITY BRION, J.
Its elements are the following: (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.[31] There is res judicata when all these requisites concur.
	GR No. 190983 2015-07-29	SURENDRA GOBINDRAM DASWANI v. BANCO DE ORO UNIVERSAL BANK BRION, J.
Res judicata exists, if the following requisites are all present: "(1) the former judgment or order had already been final; (2) the judgment or order had been on the merits; (3) it had been rendered by a court having jurisdiction over the subject matter and the parties; (4) and because of the concurrence of the first three requisites, there is now between the first and the second action, identity of parties, of subject matter and cause of action."[23]
	GR No. 195443 2014-09-17	JUANARIO G. CAMPIT v. ISIDRA B. GRIPA BRION, J.
A matter adjudged with finality by a competent court having jurisdiction over the parties and the subject matter already constitutes res judicata in another action involving the same cause of action, parties and subject matter. The doctrine of res judicata provides that a final judgment on the merits rendered by a court of competent jurisdiction, is conclusive as to the rights of the parties and their privies and constitutes as an absolute bar to subsequent actions involving the same claim, demand, or cause of action.[12] Thus, the validity of petitioner's title, having been settled with finality in Civil Case No. 15357, could no longer be reviewed in the present case.
	GR No. 182153 2014-04-07	TUNG HO STEEL ENTERPRISES CORPORATION v. TING GUAN TRADING CORPORATION BRION, J.
Res judicata refers to the rule that a final judgment or decree on the merits by a court of competent jurisdiction is conclusive on the rights of the parties or their privies in all later suits on all points and matters determined in the former suit.[19] For res judicata to apply, the final judgment must be on the merits of the case which means that the court has unequivocally determined the parties' rights and obligations with respect to the causes of action and the subject matter of the case.[20]
	GR No. 159691 2013-06-13	HEIRS OF MARCELO SOTTO v. MATILDE S. PALICTE BERSAMIN, J.
In all the five cases (Civil Case No. CEB-24293 included), a n identity of parties existed because the parties were the same, or there was privity among them, or some of the parties were successors-in-interest litigating for the same thing and under the same title and in the same capacity.[15] An absolute identity of the parties was not necessary, because a shared identity of interest sufficed for res judicata to apply.[16] Moreover, mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, would be sufficient.[17] As such, the fact that a previous case was filed in the name of the Estate of Sotto only was of no consequence.
	GR No. 156185 2011-09-12	CATALINA B. CHU v. SPS. FERNANDO C. CUNANAN BERSAMIN, J.
There is identity of parties when 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.[35] The requirement of the identity of parties was fully met, because the Chus, on the one hand, and the Cunanans, on the other hand, were the parties in both cases along with their respective privies. The fact that the Carloses and Benelda Estate, defendants in Civil Case No. 12251, were not parties in the compromise agreement was inconsequential, for they were also the privies of the Cunanans as transferees and successors-in-interest. It is settled that the absolute identity of parties was not a condition sine qua non for res judicata to apply, because a shared identity of interest sufficed.[36] Mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, was sufficient.[37]
	GR No. 165697 2009-08-04	ANTONIO NAVARRO v. METROPOLITAN BANK PERALTA, J.
The principle of res judicata 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 their former suit.[40] It obtains where a court of competent jurisdiction has rendered a final judgment or order on the merits of the case, which operates as an absolute bar against a subsequent action for the same cause.[41] A substantial identity is necessary to warrant the application of the rule, and the addition or elimination of some parties or the difference in form and nature of the two actions would not alter the situation.[42] In other words, when material facts or questions in issue in a former action were conclusively settled by a judgment rendered therein, such facts or questions constitute res judicata and may not be again litigated in a subsequent action between the same parties or their privies regardless of the form of the latter.[43]
	GR No. 163360 2007-06-08	HEIRS OF IGMEDIO* MAGLAQUE v. CA QUISUMBING, J.
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.[13]
	GR NO. 148408 2006-07-14	CONCEPCION PARAYNO v. JOSE JOVELLANOS CORONA, 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.[21] For res judicata to apply, the following elements must be present: (1) the judgment or order must be final; (2) the judgment 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 second actions, identity of parties, of subject matter and of cause of action.[22]
	GR NO. 157557 2006-03-10	REPUBLIC v. RAMON YU
The doctrine of res judicata provides that a final judgment on the merits rendered by a court of competent jurisdiction, is conclusive as to the rights of the parties and their privies and constitutes an absolute bar to subsequent actions involving the same claim, demand, or cause of action. [20] Considering that the sale on which respondents based their right to reversion has long been nullified, they have not an iota of right over the property and thus, have no legal personality to bring forth the action for reversion of expropriated property. Lack of legal personality to sue means that the respondents are not the real parties-in-interest. This is a ground for the dismissal of the case, related to the ground that the complaint evidently states no cause of action. [21]
	GR No. 162788 2005-07-28	SPS. JULITA DE LA CRUZ AND FELIPE DE LA CRUZ v. PEDRO JOAQUIN PANGANIBAN, J.
Under res judicata, 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 and on all points and matters determined in the previous suit.[43] The term literally means a "matter adjudged, judicially acted upon, or settled by judgment."[44] The principle bars a subsequent suit involving the same parties, subject matter, and cause of action. Public policy requires that controversies must be settled with finality at a given point in time.
	GR NO. 137694 2005-01-17	DEVELOPMENT BANK OF PHILIPPINES v. LA CAMPANA DEVELOPMENT CORPORATION CHICO-NAZARIO, 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.[27]
	GR No. 135365 2004-08-31	ROSARIO BARBACINA v. CA AUSTRIA-MARTINEZ, J.
The supposed differences are, however, deceptive. Note that the inclusion of the Gavino spouses as defendants in the present case is merely due to the fact that they are successors-in-interest of Cirilo Farinas. In Civil Case No. Q-28101, Rosario Farinas, the sister of Cirilo Farinas, was included because petitioner alleged therein that Rosario Farinas was actually the one interested in the subject lot, but since she had already been awarded one lot, she used the name of Cirilo Farinas to apply for the award of the subject lot. Clearly, the Gavino spouses and Rosario Farinas represent one and the same interest - that of Cirilo Farinas'. In Taganas vs. Emuslan,[7] it was held that:There is identity of parties 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.

LUZ E. TAGANAS v. MELITON G. EMUSLAN