G.R. No. 173148 , April 6, 2015
ELSA DEGAYO, Petitioner, vs. CECILIA MAGBANUA-DINGLASAN, JOHNNY DINGLASAN, ASUNCION MAGBANUA-PORRAS, MARIANO, PASCUALITO and AMADO JR., all surnamed MAGBANUA, Respondents.

FACTS

The case involves a property dispute over a parcel of land resulting from the change in the course of the Jalaud River. Petitioner Elsa Degayo owns Lot No. 861, located on the northeastern bank of the river, covered by TCT No. T-2804. Respondents collectively own Lot No. 7328, located on the opposite (southwestern) bank of the river, covered by TCT No. T-84829. In the 1970s, the river steadily changed its course, moving southwards towards and encroaching upon Lot No. 7328. This left the old riverbed dry and caused the bank adjacent to Lot No. 861 to increase in area. Degayo and her tenants believed the 52,528 sqm. area (comprising the 26,106 sqm. abandoned riverbed and 26,419 sqm. resurfaced area of Lot No. 7328) was an accretion to Lot No. 861 and began cultivating it. Respondents argued it was an abandoned riverbed belonging to them as compensation for the portion of Lot No. 7328 now occupied by the river. Respondents first filed a complaint for ownership and damages against Degayo’s tenants (Civil Case No. 16047). Degayo’s motion to intervene was denied; she did not question this but instead filed a separate suit against respondents for declaration of ownership (Civil Case No. 18328). However, she participated as a witness for the defense in Civil Case No. 16047, testifying on the same claims of inheritance, possession, and accretion. The RTC in Civil Case No. 16047 ruled in favor of the respondents, and this decision became final and executory. In Civil Case No. 18328, the RTC ruled in favor of Degayo, declaring the property an accretion. On appeal, the CA reversed the RTC, declaring the disputed property an abandoned riverbed belonging to the respondents and noting that the prior decision in Civil Case No. 16047 was conclusive under the rule on conclusiveness of judgment.

ISSUE

Whether the Court of Appeals erred in: (1) declaring the disputed property an abandoned riverbed and not an accretion; (2) taking judicial notice of the RTC decision in Civil Case No. 16047; and (3) declaring the RTC decision in Civil Case No. 16047 conclusive upon Degayo despite her not being a formal party thereto.

RULING

The Supreme Court denied the petition. The doctrine of res judicata, specifically its aspect of “conclusiveness of judgment,” bars the relitigation of issues already settled in a prior final judgment between the same parties or their privies, even if the causes of action are different. The Court found that the decision in Civil Case No. 16047 constituted res judicata on the present case. Although Degayo was not a formal party, she was in privity with her tenants, who were the defendants in that case, as they shared a community of interest and derived their claim of possession and cultivation from her. Furthermore, she actively participated in that case as a witness, testifying on the very same factual issues of ownership, possession, and accretion she raised in her own separate complaint. The Court held that allowing Degayo to relitigate these issues would violate the principles of judicial economy, stability of judgments, and the bar against vexatious litigation. Having resolved the case on the ground of res judicata, the Court deemed it unnecessary to discuss the factual issues regarding accretion versus abandoned riverbed.