G.R. No. 147958 . March 31, 2005
AIDA LUGAYAN, RONA LUGAYAN and ARTURO LUGAYAN, Petitioners, vs. SPOUSES CORAZON and ANTONIO TIZON, Respondents.

FACTS

The case originated from a sum of money case (Civil Case No. 146786-CV) filed by Travel 2000 International against petitioner Aida Lugayan. Aida was declared in default, and a decision was rendered against her. Upon finality, a writ of execution was issued, leading to the levy and auction sale of Aida’s house and lot in Las Piñas. Respondents Spouses Tizon were the highest bidders and became the registered owners. Aida subsequently filed a separate complaint for annulment of that judgment (Civil Case No. 96-79181) before the RTC of Manila.
After Aida failed to redeem the property, the Spouses Tizon filed an unlawful detainer case (Civil Case No. 5081) against the occupants, Rona and Arturo Lugayan (Aida’s siblings), before the MeTC of Las Piñas. Aida and another sibling, Diosdado, intervened as “volunteer defendants,” arguing that the property was a family home and that the detainer case was barred by litis pendentia and forum shopping due to the pending annulment case. The MeTC ruled in favor of the Spouses Tizon, a decision affirmed by the RTC and the Court of Appeals.

ISSUE

Whether the unlawful detainer case is barred by res judicata or forum shopping.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The defense of res judicata requires identity of parties, subject matter, and causes of action between the prior and subsequent cases. Here, no such identity exists. The first case (Civil Case No. 146786) was a sum of money suit between Travel 2000 International and Aida Lugayan. The second case (Civil Case No. 5081) is an unlawful detainer suit between the Spouses Tizon and the occupants (Rona and Arturo Lugayan). The subject matter and causes of action are entirely different: one involves payment of a debt, the other involves possession of real property.
Consequently, the judgment in the sum of money case cannot operate as res judicata to bar the unlawful detainer case. On the issue of forum shopping, the Court ruled that it exists only where the elements of litis pendentia are present or where a final judgment in one case would amount to res judicata in the other. Since neither condition is met, the charge of forum shopping fails. The pendency of Aida’s separate action for annulment of judgment does not preclude the ejectment suit, which seeks a different and specific relief—physical possession of the property.