This case has been cited 3 times or more.
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2015-02-11 |
VELASCO JR., J. |
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| Regarding the fourth requisite, there is identity or similarity of parties but no identity of causes of action. While Navarette is not a party in Manlangit, there is commonality or similarity of parties in the two cases. Navarette and the petitioners in Manlangit are similarly situated, being co-workers performing the same tasks of packaging, barcoding, and sealing, among others. Too, their assignment to herein respondents proceeded from the same job contracting agreement between MBI and respondents.[17] In fact, it was the petitioners in Manlangit who supported herein petitioner, Navarette, their leader, when she filed the complaint for inspection against respondents before the DOLE which, as previously mentioned, yielded a finding that there is a labor-only contracting arrangement between MBI and respondents. It is this complaint for inspection that triggered the chain of events which eventually led to the filing by therein petitioners of a complaint for regularization, later converted into one for illegal dismissal,[18] as well as Navarette's subsequent filing of her own complaint for illegal dismissal against MBI and herein respondents. Thus, based on these circumstances, there is commonality or similarity of parties. An absolute identity of parties is not necessary because a shared identity of interest will suffice for res judicata to apply. A mere substantial identity of parties or even community of interests between the parties in the prior and subsequent cases would be sufficient.[19] | |||||
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2014-07-23 |
PERALTA, J. |
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| Considering, therefore, that the RTC of Morong had long before resolved the issue of co-ownership against petitioner in his complaint for Partition of Real Property, which was affirmed with finality by this Court, no less, petitioner's subsequent claim for Recovery of Property or its Value must likewise necessarily fail. To reiterate, even if the forms or nature of actions in both cases are different, since the issues raised essentially involve the claim of ownership over the subject property, there is identity of the causes of action.[40] | |||||
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2014-03-05 |
BRION, J. |
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| We agree with the CA that the petitioners committed forum shopping when they filed the specific performance case despite the pendency of the present case before the CA. In the recent case of Heirs of Marcelo Sotto, etc., et al. v. Matilde S. Palicte,[26] the Court laid down the three ways forum shopping may be committed: 1) through litis pendentia filing multiple cases based on the same cause of action and with the same prayer, the previous case not having been resolved yet; 2) through res judicata filing multiple cases based on the same cause of action and the same prayer, the previous case having been finally resolved; and 3) splitting of causes of action filing multiple cases based on the same cause of action but with different prayers the ground to dismiss being either litis pendentia or res judicata. "The requisites of litis pendentia are: (a) the identity of parties, or at least such as representing the same interests in both actions; (b) the identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (c) the identity of the two cases such that judgment in one, regardless of which party is successful, would amount to res judicata in the other."[27] | |||||