G.R. No. L-22551. March 16, 1971.
WONG SAU MEI and ANASTACIO RABO (Ta Ching Ta), petitioners-appellees, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Petitioner Wong Sau Mei, a Chinese citizen, entered the Philippines as a temporary visitor. She married co-petitioner Anastacio Rabo, who claimed to be a natural-born Filipino citizen. Wong Sau Mei subsequently filed a petition with the Bureau of Immigration for the cancellation of her Alien Certificate of Registration, contending she had acquired Filipino citizenship by virtue of her marriage. The Commissioner of Immigration denied her petition, citing the ruling in Lee Suan Ay that marriage does not automatically confer citizenship. The petitioners then filed a petition for mandamus and prohibition with the Court of First Instance (CFI) of Manila, which was dismissed. Their appeal to the Court of Appeals was also dismissed for failure to file a brief.
While that appeal was pending, the petitioners filed a new and separate petition with the CFI of Camarines Norte, praying that Wong Sau Mei “be allowed to follow or to acquire Filipino citizenship by virtue of her marriage.” The Solicitor General opposed, arguing that under Section 15 of Commonwealth Act No. 473, an alien wife is deemed a citizen only if she “might herself be lawfully naturalized,” which requires possessing all qualifications and none of the disqualifications. The CFI of Camarines Norte granted the petition, declaring Wong Sau Mei a Filipino citizen. The Republic appealed.

ISSUE

Whether the petition filed in the CFI of Camarines Norte is barred by res judicata due to the prior final judgment in the Manila CFI case.

RULING

Yes, the petition is barred by res judicata. The Supreme Court reversed the decision of the CFI of Camarines Norte. The doctrine of res judicata provides that a final judgment on the merits rendered by a court of competent jurisdiction is conclusive as to the rights of the parties and constitutes an absolute bar to subsequent actions involving the same claim, demand, or cause of action. For res judicata to apply, there must be: (1) a former final judgment; (2) a court with jurisdiction over the subject matter and parties; (3) a judgment on the merits; and (4) identity of parties, subject matter, and causes of action between the first and second actions.
All these elements are present. The dismissal of the petitioners’ appeal in the Manila case by the Court of Appeals for failure to file a brief resulted in a final judgment on the merits of that case. The parties in both cases are identical: the petitioners are the same, and the Republic of the Philippines, represented by the Solicitor General, is the oppositor. The acting Commissioner of Immigration in the first case was merely a nominal party representing the Republic. The subject matter and cause of action are also identical, as both petitions essentially sought the same judicial declaration that Wong Sau Mei acquired Philippine citizenship through marriage to a Filipino citizen. The allegations in both petitions were substantially the same. Therefore, the petitioners were foreclosed from re-litigating the same issue in a different court. The petition was correctly denied on this ground.