G.R. No. 141501 ; July 21, 2006
ELINO RIVERA, DOMINADOR CLAUREN, SOLEDAD CLAUREN DE RIVERA, TEOFILA RIVERA and CECILIA RIVERA, petitioners, vs. HEIRS OF ROMUALDO VILLANUEVA represented by MELCHOR VILLANUEVA, ANGELINA VILLANUEVA, VICTORIANO DE LUNA, CABANATUAN CITY RURAL BANK, INC. and REGISTER OF DEEDS OF NUEVA ECIJA, respondents.

FACTS

Petitioners, claiming to be the half-siblings and nieces of the deceased Pacita Gonzales, filed a case for partition and annulment of titles against respondents, the heirs of Romualdo Villanueva. Gonzales and Villanueva cohabited from 1927 until her death in 1980, acquiring several properties registered in their names, as Villanueva was legally married to another until 1963. After Gonzales’s death, Villanueva and respondent Angelina Villanueva executed an extrajudicial partition of Gonzales’s estate, with Villanueva conveying his interests to Angelina, whom he claimed was Gonzales’s illegitimate child.
The Regional Trial Court dismissed the petitioners’ complaint, finding that Gonzales and Villanueva were never married and that Angelina was the illegitimate daughter of Gonzales and, thus, her sole heir to the exclusion of the petitioners. The Court of Appeals affirmed this decision. Petitioners now argue that a prior intestate estate proceeding (Special Proceedings No. SD-144), where the trial court found Angelina was neither the adopted nor illegitimate daughter of Gonzales, should operate as res judicata on the issue of her filiation in the present partition case.

ISSUE

The primary issues are: (1) whether the finding in the prior intestate proceeding that Angelina was not Gonzales’s daughter constitutes res judicata in the instant partition case; and (2) whether the properties acquired by Gonzales and Villanueva during their cohabitation are owned in equal shares.

RULING

The Supreme Court denied the petition. On the first issue, res judicata does not apply. For res judicata to bar an action, there must be, among other elements, identity of parties and causes of action between the prior and subsequent cases. Here, the parties were different. The prior intestate case was filed by Epifanio Rivera against Romualdo Villanueva alone. The present partition case was filed by different petitioners against the heirs of Villanueva and Angelina. Epifanio Rivera was not a party herein, and there was no showing he represented the petitioners’ interests in the prior case. The absence of identity of parties precludes the application of res judicata.
On the merits, the Court upheld the finding that Angelina is the illegitimate daughter of Gonzales. The evidence, including her birth certificate and Gonzales’s own affidavit, substantiated this filiation. Consequently, as an illegitimate child, Angelina is the sole heir of Gonzales under the law then in force, excluding the petitioners who are mere collateral relatives. Regarding property relations, properties registered in the names of both Gonzales and Villanueva are presumed to be owned in common and in equal shares under Article 144 of the Civil Code (governing cohabitation without marriage). Thus, upon Gonzales’s death, her one-half share in the co-owned properties passed exclusively to her heir, Angelina.