G.R. No. L-61049 April 15, 1985
HEIRS OF MATILDE CENIZAL ARGUSON, represented by ALBERTO ARGUSON, plaintiffs-appellants, vs. REMEDIOS MECLAT, defendant-appellee.

FACTS

The plaintiffs-appellants, heirs of Matilde Cenizal Arguson, filed a complaint for reconveyance and surrender of a one-half portion of land covered by TCT No. 80392, plus damages, against defendant Remedios Miclat. They alleged that Matilde and her brother Apolinar jointly inherited the land from their father. However, an “Instrument of Recognition and Confirmation” dated February 29, 1972, was executed, making it appear that the land had been sold to Juan Miclat, Remedios’s predecessor. Based on this, Juan later sold the land to Remedios, who obtained title. The plaintiffs averred that in a prior decision dated June 13, 1978, in Civil Case No. NC-676, the same court had already declared that instrument null and void. They argued that Apolinar could only dispose of his one-half share, making the transfer of the entire property to Remedios improper.
The defendant-appellee moved to dismiss the complaint on the ground of res judicata, citing the prior judgment in Civil Case No. NC-676. She contended that the issue of ownership over the land had already been resolved in her favor in that case. The lower court agreed, granting the motion to dismiss. The plaintiffs appealed, arguing that the cause of action in the first case was for annulment of an instrument, while the present action was for partial reconveyance, and thus the causes of action were different, barring the application of res judicata.

ISSUE

Whether the principle of res judicata bars the instant complaint for partial reconveyance, given the prior final judgment in Civil Case No. NC-676 which declared an instrument null and void but recognized the defendant’s ownership.

RULING

Yes, res judicata applies. The Supreme Court affirmed the dismissal. The requisites for res judicata are present: a final former judgment rendered by a court with jurisdiction on the merits, and identity of parties, subject matter, and cause of action between the two suits. The Court found identity of parties and subject matter undisputed. On the critical element of identity of cause of action, the test is whether the same evidence would support both the former and present causes of action. Here, both the action for annulment of the instrument and the action for reconveyance were fundamentally anchored on the plaintiffs’ asserted right of ownership over the property. The evidence required to prove ownership would be identical in both cases.
The Court emphasized that a different form of action or remedy sought does not preclude res judicata. The prior decision in Civil Case No. NC-676 did not merely annul the instrument; it also expressly recognized and upheld the present ownership of defendant Remedios Miclat over the land. Therefore, the ownership issue had already been adjudicated. Allowing the second suit would permit the litigation of the same issue anew, contravening the doctrine of res judicata, which aims to prevent multiplicity of suits and ensure finality of judgments. The order of dismissal was proper.