G.R. No. 114275 July 7, 1997
IÑIGO F. CARLET, as Special Administrator of the Estate of Pablo Sevillo and Antonia Palisoc, petitioner, vs. HON. COURT OF APPEALS, VIRGINIA C. ZARATE, JACOBO C. ZARATE, VICTORIA C. ZARATE, HON. CONRADO DIZON, Acting Judge of the Municipal Trial Court of Biñan, Laguna, and DEPUTY SHERIFF ROGELIO S. MOLINA of Biñan, Laguna, respondents.

FACTS

Lot 981 was purchased by Jose Sevillo. He had four sons, including Pablo Sevillo. Pablo married Antonia Palisoc, with whom he had four children. After Antonia’s death, Pablo married Candida Baylo, who had a daughter from a previous relationship, Cirila Baylo Carolasan. In 1965, Pablo and Candida secured the reconstitution of title, and TCT No. RT-926 was issued in Pablo’s name, married to Candida. After Pablo and Candida died, the heirs of Cirila (the Zarates) filed Civil Case No. B-1656 in 1980 for annulment of a deed of sale over Lot 981 and for partition. The trial court declared the deed void and ordered partition. This decision became final and executory, and the Zarates obtained titles to their share. The Sevillos’ subsequent petition to annul this decision was dismissed by the appellate court and the Supreme Court (G.R. No. 74505). The Zarates also filed an ejectment suit (Civil Case No. 2375) against the Sevillos, which ultimately reached the Supreme Court ( G.R. No. 94382 ) and was decided in the Zarates’ favor. In 1991, petitioner Iñigo F. Carlet, as special administrator of the estate of Pablo and Antonia, filed Civil Case No. B-3582 for reconveyance of property, seeking to annul the Zarates’ titles and declare ownership in favor of the estate of Jose Sevillo and/or his sons. The Zarates moved to dismiss on the ground of res judicata. The trial court granted the motion and dismissed the case. The Court of Appeals affirmed the dismissal.

ISSUE

Whether or not the adjudication in Civil Case No. B-1656 (including its appellate proceedings) constitutes res judicata, thereby barring the present action for reconveyance (Civil Case No. B-3582).

RULING

Yes, the principle of res judicata applies. The Supreme Court affirmed the decision of the Court of Appeals. For res judicata to apply, four requisites must concur: (a) finality of the former judgment; (b) the rendering court had jurisdiction; (c) it is a judgment on the merits; and (d) identity of parties, subject matter, and cause of action between the first and second actions. The first three requisites are present and undisputed. Regarding the fourth requisite, there is identity of parties because petitioner, as administrator of Pablo and Antonia’s estate, represents the same heirs of Pablo Sevillo (his children) who were defendants in Civil Case No. B-1656. There is identity of subject matter as both cases concern Lot 981. There is identity of cause of action because the issue of ownership over Lot 981 was already conclusively settled in Civil Case No. B-1656, wherein the court ordered its partition among the heirs, including the Zarates. The action for reconveyance in the present case is essentially an attempt to relitigate the same issue of ownership under a different guise. Therefore, the present action is barred by prior judgment.