G.R. No. 211755 . October 07, 2020
HEIRS OF FELICISIMO GABULE, ET AL., PETITIONERS, VS. FELIPE JUMUAD, SUBSTITUTED FOR BY HIS HEIRS, RESPONDENTS.

FACTS

Respondent Felipe Jumuad filed an action for reconveyance and damages against petitioners, the heirs of Felicisimo Gabule. He alleged that Gabule, through fraud in his application for an original certificate of title (OCT No. 1817), encroached upon a portion of Jumuad’s lot. This encroachment was identified as a strip of land measuring 50m by 3.78m. Prior to this case, a separate action for reconveyance involving the same property was filed by Severino Saldua against the same Gabule heirs. In that prior case (Civil Case No. 2973), Saldua claimed ownership over a portion designated as Lot No. 2857-B, alleging it was fraudulently included in Gabule’s title. The RTC dismissed Saldua’s complaint, ruling he had no remaining interest in the lot, a decision which became final and executory.
In the present case, the RTC initially ruled in favor of Jumuad, ordering reconveyance based on constructive fraud. However, upon motion by the Gabule heirs, the RTC set aside its own decision. The Court of Appeals reversed the RTC’s order and reinstated the decision favoring Jumuad. The Gabule heirs elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the action for reconveyance filed by respondent Felipe Jumuad is barred by the principle of res judicata.

RULING

Yes, the action is barred by res judicata. For res judicata to apply, the following must concur: (1) a final former judgment; (2) a court of competent jurisdiction rendered the judgment; (3) the judgment is on the merits; and (4) there is identity of parties, subject matter, and causes of action between the first and second actions. All these elements are present. The prior case filed by Saldua resulted in a final judgment on the merits by a court of competent jurisdiction. Critically, there is identity of causes of action and subject matter. Both Saldua’s and Jumuad’s complaints sought reconveyance of the same property, Lot No. 2857-B, included in Gabule’s OCT No. 1817, based on the same alleged fraud in the titling process. The identity of parties is established through shared interests. Jumuad, in his testimony in the Saldua case, confirmed he was the source of Saldua’s claim, effectively making them privies-in-interest. A party is a privy if, after the commencement of the action, he has acquired an interest in the subject matter through one of the parties. By testifying to support Saldua’s claim of ownership derived from him, Jumuad aligned his interests with Saldua’s, making him bound by the judgment against Saldua. Consequently, Jumuad’s separate action constitutes forbidden splitting of a cause of action and is barred by res judicata. The Supreme Court granted the petition, reversing the CA and reinstating the RTC order which found Jumuad had no cause of action.