G.R. No. 107349 September 26, 1994
SUNFLOWER UMBRELLA MANUFACTURING CO., INC., petitioner, vs. BETTY U. DE LEON and THE HONORABLE COURT OF APPEALS, respondents.

FACTS

In 1976, private respondent Betty U. de Leon filed Civil Case No. Q-22325 to establish a compulsory easement of right of way over adjoining lots, claiming her property was isolated. The trial court granted the easement in 1980, and the Court of Appeals modified and affirmed this judgment in CA-G.R. CV No. 01437 in 1988, which became final and executory. The appellate court’s decision remanded the case to the trial court to determine the exact measurements of the area affected by the right of way.
In 1989, petitioner Sunflower Umbrella Manufacturing Co., Inc. purchased a portion of the servient estate from the heirs of a defendant in the first case. Subsequently, in 1990, de Leon filed a supplemental complaint in the original case to implead Sunflower. Alleging that de Leon’s relatives had acquired a southern property in 1974, which could provide an outlet and thus extinguish the need for the easement, Sunflower initiated a separate action, Civil Case No. Q-90-6576, seeking to extinguish the easement. The trial court consolidated this new case with the original one and deferred resolution of de Leon’s motion to dismiss.

ISSUE

Whether the principle of res judicata bars Sunflower’s subsequent action for the extinguishment of the easement.

RULING

Yes, res judicata applies. The Supreme Court affirmed the Court of Appeals’ dismissal of Sunflower’s petition. For res judicata to bar a subsequent action, there must be, among other elements, identity of parties or their successors-in-interest. Sunflower, as a purchaser of a portion of the servient estate after the commencement of the first case, is a successor-in-interest bound by the final judgment in Civil Case No. Q-22325. A notice of lis pendens was annotated on the title, constituting constructive notice and subjecting the property to the outcome of that litigation.
The relief sought in the second action—extinguishment of the easement—is inconsistent with the final judgment establishing it in the first. A change in the form of the action or the relief sought does not preclude the application of res judicata to prevent double vexation. The Court noted that Sunflower’s basis for claiming extinguishment (the 1974 acquisition) existed even before the first case was filed in 1976, making it improper to relitigate the matter. However, the ruling does not foreclose a future action for extinguishment should there be a subsequent change in the condition of the estates.