GR 157557; (March, 2006) (Digest)
G.R. No. 157557 ; March 10, 2006
REPUBLIC OF THE PHILIPPINES (CIVIL AERONAUTICS ADMINISTRATION), Petitioner, vs. RAMON YU, TEOFISTA VILLAMALA, LOURDES YU and YU SE PENG, Respondents.
FACTS
This case involves Lot No. 939 in Lahug, Cebu City, which was expropriated by the Republic in the 1966 case of Valdehueza v. Republic. The Court affirmed the expropriation, ruling the owners were entitled only to payment, not repossession. Subsequently, the original owners sold the lot to respondents Ramon Yu, et al. In the 1986 case of Yu v. Republic, the Court of Appeals annulled this sale, declaring the Republic as owner and finding respondents were not purchasers in good faith. This judgment became final.
In 1992, respondents filed a new complaint for reversion of the expropriated property, arguing the government had abandoned the public purpose for the airport. The Republic moved to dismiss on grounds of res judicata, lack of cause of action, and forum-shopping. The Regional Trial Court dismissed the complaint on the ground of res judicata. The Court of Appeals reversed, finding no res judicata and remanded the case for trial on the merits.
ISSUE
The primary issue is whether the complaint for reversion is barred by the doctrine of res judicata.
RULING
Yes, the action is barred by res judicata, specifically under the concept of “conclusiveness of judgment.” The Supreme Court reversed the Court of Appeals and reinstated the trial court’s dismissal. For res judicata to apply, the following must concur: (1) a prior final judgment; (2) rendered by a court with jurisdiction; (3) on the merits; and (4) identity of parties, subject matter, and causes of action (or, for conclusiveness of judgment, identity of issues).
The first three elements are undisputed. The final and executory judgment in Yu v. Republic definitively settled that the sale to respondents was invalid and that the Republic is the rightful owner of Lot No. 939. While the causes of action in Yu v. Republic (annulment of sale) and the present case (reversion) are technically different, the doctrine of “conclusiveness of judgment” applies. This doctrine holds that facts and issues actually and directly resolved in a former suit are conclusive between the same parties in any future case, even on a different claim.
The core issue of respondents’ right to assert ownership based on the annulled sale was directly and conclusively adjudicated in Yu v. Republic. Respondents, being privies to the original sellers, cannot re-litigate this settled issue under a new cause of action. The alleged abandonment of the public purpose does not create a new right in respondents, whose claim to title was already extinguished by the final judgment annulling their purchase. Therefore, the complaint was correctly dismissed.