GR 99375; (February, 1995) (Digest)
G.R. No. 99375 . February 1, 1995.
GLICERIO MANGOMA, petitioner, vs. COURT OF APPEALS, FLORIDA ESPIRITU-SANCHEZ, NORMA FLORES, SPOUSES SABINO PALOMARES, JR., and MATILDE ARGUELLES and NAPOLEON TORRICO, JR., respondents.
FACTS
Private respondent Florida Espiritu-Sanchez and her mother were the registered owners of a parcel of land. They entered into an agreement with Pedro del Rosario for him to develop a portion into a subdivision, with the owners to execute deeds of sale upon full payment by buyers. Petitioner Glicerio Mangoma subsequently entered into a “Contract to Sell” with Del Rosario for the purchase of subdivision lots, with Del Rosario guaranteeing recognition by the owners. When his demands for deeds of sale and titles went unheeded, Mangoma filed an action for specific performance against Del Rosario and the Espiritus. The trial court and later the Court of Appeals dismissed the complaint against the Espiritus, ruling the contract was purely between Mangoma and Del Rosario, creating no obligation for the non-party registered owners. This decision became final.
Subsequently, the Espiritus began selling the lots to other buyers. Mangoma then filed a new action for annulment of title against Sanchez and the new buyers. Sanchez moved to dismiss on the ground of res judicata, citing the final decision in the specific performance case. The trial court denied the motion, finding no identity of subject matter or cause of action between the two cases. The Court of Appeals reversed, ordering the dismissal of the new case.
ISSUE
Whether the defense of res judicata is legally tenable to bar Mangoma’s action for annulment of title.
RULING
Yes, res judicata applies. The Supreme Court affirmed the Court of Appeals. The elements of res judicata are present: a final judgment on the merits by a court of competent jurisdiction, and identity of parties, subject matter, and cause of action between the prior and subsequent cases. The Court clarified that while the specific lots may have been enumerated differently, the subject matter in both cases is fundamentally the same: Mangoma’s claim of rights over the subdivision lots based on the contract with Del Rosario. The cause of action also springs from the same source—the 1964 Contract to Sell.
The final ruling in the specific performance case that the Espiritus were not parties to and not bound by the contract between Mangoma and Del Rosario constitutes the “law of the case.” This conclusive determination that Mangoma has no cause of action against the registered owners based on that contract is binding and cannot be relitigated under a different guise, such as an action for annulment of title. The defense of res judicata therefore absolutely bars the second suit.