GR 126207; (August, 2005) (Digest)
G.R. No. 126207 . August 25, 2005.
AMANTE O. SAN PEDRO, Petitioner, vs. MARCIANA M. BINALAY, assisted by her husband ROBERTO BULURAN and WILSON M. BINALAY, Respondents.
FACTS
Petitioner Amante San Pedro initially filed a complaint for “Specific Performance with Damages” (Civil Case No. 3467) against respondents, seeking to compel them to register a deed of absolute sale and to have a certificate of title issued in his name for a specific parcel of land. Respondents denied executing the deed, alleging it was fictitious. After pre-trial but before presenting evidence, San Pedro filed a Motion to Withdraw his complaint. Respondents agreed, provided the dismissal was with prejudice. The trial court, in an Order dated August 27, 1990, granted the motion and dismissed the case “with prejudice,” also dismissing respondents’ counterclaim.
Over a year later, San Pedro filed a new complaint against the same respondents for “Recovery of Possession and Ownership with Damages” (Civil Case No. 4404) over the identical parcel of land. Respondents moved to dismiss on the ground of res judicata, citing the prior dismissal with prejudice. The trial court granted the motion to dismiss, a decision affirmed by the Court of Appeals.
ISSUE
Whether the doctrine of res judicata bars the second action (Civil Case No. 4404) despite the petitioner’s claim of a different cause of action.
RULING
Yes, the doctrine of res judicata applies. The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic is anchored on the conclusive effect of a dismissal with prejudice. A dismissal “with prejudice” signifies an adjudication on the merits, which constitutes res judicata as to every matter offered and received in the first action, as well as to any other admissible matter that could have been offered.
The Court rejected San Pedro’s argument that the causes of action differedβthe first being for specific performance and the second for recovery of possession and ownership. The determinative factor is not the formal title of the action but the factual circumstances from which the relief is sought. Both complaints were fundamentally rooted in the same alleged deed of sale and sought to establish San Pedro’s ownership over the same property. Since the first case was dismissed with prejudice upon his own motion, he is barred from re-litigating any claim arising from the same transaction or series of transactions, including the present action for recovery. The Court emphasized that equity cannot aid a party who seeks to evade the finality of a dismissal he himself sought, especially where, as here, the authenticity of the foundational deed is highly suspect.
