G.R. No. 209535, June 15, 2015
Teresita S. Lee, Petitioner, vs. Lui Man Chong, Respondent.

FACTS

Conrado P. Romero died intestate on January 17, 2006, leaving properties including four parcels of land in Baguio City and shares in Pines Commercial Corporation. On February 23, 2006, respondent Lui Man Chong, claiming to be Romero’s nephew, executed an “Affidavit of Self-Adjudication,” adjudicating the entire estate to himself and transferring titles to his name. Petitioner Teresita S. Lee, claiming to be Romero’s common-law wife, filed a “Petition for Letters of Administration” (Special Proceedings Case No. 1646-R), which was dismissed and eventually affirmed by the Supreme Court. On August 24, 2006, Lee, with another, filed a complaint for “Declaration of Nullity of Affidavit of Self-Adjudication” (Annulment Case, Civil Case No. 6328-R) against Chong, claiming co-ownership of half of Romero’s estate. The Regional Trial Court (RTC) Branch 61 dismissed this case on April 29, 2008, for lack of cause of action and legal personality, stating Lee did not qualify as an heir under the Civil Code and failed to establish cohabitation. This dismissal attained finality on January 12, 2009. On September 4, 2008, Lee filed another case for “Annulment of Title with Damages,” later amended to “Recovery of Ownership” (Recovery Case, Civil Case No. 6761-R) against Chong before RTC Branch 60, alleging she was Romero’s common-law wife and business partner and co-owner of the properties acquired during cohabitation, seeking cancellation of titles in Chong’s name and issuance of new ones for her half-share. Chong moved to dismiss the Recovery Case on grounds including res judicata, citing the final judgments in the Special Proceedings and Annulment Cases. Initially denied, the RTC Branch 60, upon reconsideration, dismissed the Recovery Case on August 8, 2011, on the ground of res judicata, reasoning that the issue of the affidavit’s validity and co-ownership had been settled with finality in the Annulment Case. The Court of Appeals affirmed this dismissal, applying the doctrine of res judicata (bar by prior judgment).

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the Recovery Case on the ground of res judicata.

RULING

The Supreme Court denied the petition, finding no reversible error. The doctrine of res judicata (bar by prior judgment) applied, as all its elements were satisfied: (1) the prior Annulment Case judgment was final (attained finality on January 12, 2009); (2) the RTC Branch 61 had jurisdiction and rendered a judgment on the merits; (3) there was identity of parties (both cases involved Lee and Chong); (4) there was identity of subject matter (both involved the same properties); and (5) there was identity of causes of action (both sought recovery of ownership of half the properties based on Lee’s claim of co-ownership as common-law spouse, with the same relief ultimately sought). The Court noted that the dismissal of the Annulment Case was an adjudication on the merits, as it determined the parties’ rights and obligations, and that the causes of action in both cases were identical, as they arose from the same act of deprivation by Chong’s affidavit. Thus, the Recovery Case was barred by the prior judgment in the Annulment Case.