G.R. No. 135365 ; August 31, 2004
ROSARIO BARBACINA, petitioner, vs. HONORABLE COURT OF APPEALS, SPOUSES RICHARD GAVINO AND MA. OLIVIA AMORIN GAVINO, CIRILO FARINAS AND THE REGISTER OF DEEDS OF QUEZON CITY AND NATIONAL HOUSING AUTHORITY (NHA) FORMERLY PEOPLE’S HOMESITE AND HOUSING CORPORATION (PHHC), respondents.

FACTS

Petitioner Rosario Barbacina filed a complaint for annulment of title, seeking to nullify the Conditional Contract to Sell and Deed of Sale executed by the NHA in favor of respondent Cirilo Farinas, and to cancel the subsequent Transfer Certificates of Title issued to Farinas and the respondent spouses Gavino. Barbacina alleged she had been in open, adverse possession of the subject Quezon City lot for over fifty years, had applied for its award from the NHA, and that Farinas was a non-resident, unqualified awardee. She contended the award and titles were void, especially as Farinas failed to comply with a title condition to construct a house within one year.
Respondents moved to dismiss on the ground of res judicata, citing two prior cases (Civil Case Nos. Q-28101 and Q-43359) involving the same parties and the same property. In the first case, the trial court dismissed Barbacina’s complaint for cancellation of title, ruling her possession could not override Farinas’s ownership and that her action was filed beyond the one-year period from title issuance. The second case dismissed her petition for injunction against the NHA on the precise ground of res judicata, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the present action for annulment of title is barred by res judicata.

RULING

Yes, the action is barred. The Supreme Court affirmed the lower courts’ dismissal, holding all elements of res judicata are present. There is identity of parties, subject matter, and causes of action between the present case and the prior litigation. The core issue in the first case (Civil Case No. Q-28101) was the validity of the NHA’s award of the lot to Cirilo Farinas and the title issued in his name. This is the identical fundamental issue Barbacina re-litigates, notwithstanding her attempt to frame new ancillary issues regarding Farinas’s qualifications, compliance with title conditions, and the validity of the subsequent sale to the Gavino spouses.
The legal logic is that a final judgment on the merits constitutes an absolute bar to a subsequent action involving the same claim, demand, or cause of action. The parties are bound not only as to every matter offered and received to sustain or defeat the claim but also as to any other admissible matter which could have been offered for that purpose. Therefore, all issues which were or could have been raised in the prior action, including those pertaining to the validity of the award and title, are deemed conclusively settled. The philosophy is to prevent endless litigation, ensure judicial stability, and protect parties from the vexation of re-litigating the same issue. The present complaint, seeking the same ultimate relief of nullifying the award and titles based on the same factual premise, is barred by the prior final judgment.