GR 142401; (August, 2001) (Digest)
G.R. No. 142401 ; August 20, 2001
ANDREW TAN, petitioner, vs. COURT OF APPEALS and WU SEN WOEI, respondents.
FACTS
Petitioner Andrew Tan (Filipino) and respondent Wu Sen Woei (Taiwanese) met in Taiwan in August 1987. Tan proposed that Wu invest in his hatchery business, and Wu gave him $80,000. After Tan repaid only $10,000, Wu lodged a complaint with the NBI. Before the NBI on July 19, 1990, Tan and his sister Helen Go signed a Joint Affidavit of Undertaking acknowledging a $70,000 debt to Wu and setting a payment schedule. Tan later claimed he signed under duress and filed a civil case (Civil Case No. D-9864) before the RTC of Dagupan City to annul the Undertaking. The RTC declared the Undertaking null, but the Court of Appeals (CA) in CA-G.R. CV No. 47880 reversed the RTC and dismissed Tan’s complaint, upholding the Undertaking’s validity. That CA decision became final. Meanwhile, based on the Undertaking, Wu collected an additional $25,000, leaving a $45,000 balance. Wu then filed the present collection suit (Civil Case No. 91-55981) to recover this balance.
ISSUE
Whether the Court of Appeals committed a grave error in applying the doctrine of conclusiveness of judgment to bar the relitigation of the validity of the Affidavit of Undertaking in the present collection case.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision. The doctrine of conclusiveness of judgment (or collateral estoppel) applies. Under this doctrine, facts and issues actually and directly resolved in a former suit cannot be raised again in any future case between the same parties, even if the latter suit involves a different cause of action. The validity of the Affidavit of Undertaking was already conclusively settled with finality in CA-G.R. CV No. 47880, where the CA upheld it as a valid admission of debt. Therefore, Tan could not relitigate the issue of its nullity (based on duress) in the subsequent collection case. The identity of issues (the Undertaking’s validity) between the two cases, despite the different causes of action (annulment vs. collection), triggers the application of the doctrine. The Court also noted that Tan’s conduct—making payments per the Undertaking and his counsel requesting payment extensions—contradicted his claim of duress.