G.R. No. 151339 ; January 31, 2006
Editha M. Francisco, Petitioner, vs. Roque Co and/or Mariano Co, Respondents.

FACTS

The dispute involves a parcel of land originally owned by Pastora Baetiong. In 1983, her heirs (including petitioner Editha Francisco) and respondents Roque and Mariano Co settled Civil Case No. Q-38464 via a Compromise Agreement, later embodied in a Contract of Lease. The agreement acknowledged the heirs’ ownership and leased approximately 30,000 sq.m. to respondents for 15 years. In 1990, the Court of Appeals, in CA-G.R. SP No. 18032, ruled that this judgment by compromise was “finally terminated and executed,” precluding any further action to delineate the leased area. This 1990 Decision became final.
In 1995, petitioner filed a forcible entry complaint (Civil Case No. 13158) before the MeTC, alleging respondents unlawfully entered and fenced her specific subdivided lot, Lot 2-F-4 (5,679 sq.m.), which she inherited. Respondents asserted this lot was covered by the 1983 lease and that the action was barred by res judicata due to the final 1990 CA Decision. The MeTC and RTC ruled for petitioner, finding no res judicata as the causes of action differed (forcible entry vs. execution of lease) and that Lot 2-F-4 was excluded from the leased area. The Court of Appeals reversed, holding the complaint was barred.

ISSUE

Whether the principle of res judicata bars the petitioner’s action for forcible entry.

RULING

Yes, the action is barred by res judicata. The Supreme Court affirmed the Court of Appeals, applying the doctrine of “conclusiveness of judgment.” For this species of res judicata to apply, the following must concur: (1) a former final judgment; (2) the former judgment is on the merits; (3) it was rendered by a court having jurisdiction; and (4) there is identity of parties and subject matter, but not necessarily of causes of action. All these elements are present.
The 1990 CA Decision, which attained finality, constitutes a final judgment on the merits by a competent court. The parties are identical—petitioner (as an heir of Baetiong) and respondents. The subject matter is identical: the parcel of land covered by TCT No. 44546 and the extent of the area leased to respondents under the 1983 Compromise Agreement and Contract of Lease. The CA had conclusively ruled that the compromise judgment was fully executed and terminated, and it specifically addressed and rejected the heirs’ claim that respondents were occupying an area exceeding the 30,000 sq.m. leasehold. By filing the forcible entry case, petitioner essentially sought to relitigate the very issue of the precise metes and bounds of the leased property—an issue already settled with finality. The difference in the form of action (forcible entry) is immaterial; the core issue of the land’s occupancy under the lease had been adjudicated. Thus, the present complaint is barred. The Court modified the CA decision by deleting the awards of moral damages, exemplary damages, and attorney’s fees for lack of basis.