G.R. No. L-53564 February 27, 1987
JUAN BAYANG, petitioner, vs. HON. COURT OF APPEALS and BENIGNO BIONG, respondents.

FACTS

Juan Bayang filed a complaint for quieting of title against Benigno Biong in 1969 (Civil Case No. 1892). While this case was pending, Biong dispossessed Bayang of the land in 1970 and remained in possession. The trial court initially decided for Biong in 1972, but the Court of Appeals reversed this decision on December 8, 1977, declaring Bayang the owner and ordering Biong to pay a specific sum for a share of copra proceeds and attorney’s fees. This CA decision became final on February 2, 1978. Biong surrendered possession of the land to Bayang on January 25, 1978.
On February 6, 1978, Bayang filed a second case (Civil Case No. 2589) to recover the incomes Biong earned from the land from 1970 until its delivery in 1978. Biong moved for summary judgment, asserting the defense of res judicata, arguing the claim for incomes was barred by the final judgment in the first case. The trial court granted the motion, and the Court of Appeals sustained this decision. Bayang petitioned the Supreme Court, contesting the propriety of summary judgment and the application of res judicata.

ISSUE

Whether the trial court correctly granted summary judgment based on the affirmative defense of res judicata, thereby barring Civil Case No. 2589.

RULING

The Supreme Court ruled for the respondents, affirming the dismissal of Civil Case No. 2589. Summary judgment was proper as no genuine issue of fact existed, given the conclusive application of res judicata. The Court held that all elements of res judicata were present: the judgment in Civil Case No. 1892 was final, rendered by a court with jurisdiction, on the merits, and there was identity of parties, subject matter, and cause of action between the two cases.
The Court rejected Bayang’s argument that the claim for income constituted a separate cause of action from the claim for ownership of the land. It ruled that the income was merely an accessory or consequence of the property right adjudicated in the first case. Therefore, the claim for such income was incidental to and should have been raised in the earlier litigation for ownership. Bayang’s failure to amend his complaint in the first case to include a claim for the incomes earned during its pendency (from 1970 onward) meant the right to recover them was deemed waived. The principle against splitting a cause of action applies, and the final judgment in the first case bars the subsequent claim. The petition was dismissed.