G.R. No. 226043, February 03, 2020
HEIRS OF SALVADOR AND SALVACION LAMIREZ, NAMELY MARTHA, JHONY, AND JAVIER LAMIREZ, REPRESENTED BY DOLORES PARREÑAS; HEIRS OF ALFONSO AND FLORINDA ESCLADA, NAMELY ABELARDO, ALFREDO, HELEN, MARILYN, ELIZABETH, AND ALFONSO, JR., REPRESENTED BY GILDA E. LACANDULA; AND HEIRS OF PROVIDENCIA AND RODRIGO LLUPAR, REPRESENTED BY ETHELDA LLUPAR, PETITIONERS, VS. SPOUSES AHMED AMPATUAN AND CERILA R. AMPATUAN, RESPONDENTS.

FACTS

A land dispute over Lot No. 1562-B, Pls-397-D in Allah, Esperanza, Sultan Kudarat between the Lamirez Spouses, Esclada Spouses, and Llupar Spouses (collectively, Lamirez Spouses, et al.) and the Ampatuan Spouses was brought before the Bureau of Lands in 1981. On June 18, 1996, the parties entered into a Compromise Agreement. It stipulated that the disputed property would be titled in the names of the Ampatuan Spouses, who would then offer it for sale to the government under the Comprehensive Agrarian Reform Program (CARP) via Voluntary Offer to Sell (VOS), with the Lamirez Spouses, et al. as the beneficiaries. The Bureau of Lands issued titles to the Ampatuan Spouses on February 28, 1997, and the Compromise Agreement became the basis for resolving the land dispute.
Subsequently, the Ampatuan Spouses filed a case for recovery of possession and back rentals against the Lamirez Spouses, et al. before the Provincial Agrarian Reform Adjudicator (PARAD), alleging the latter refused to pay back rentals. The Lamirez Spouses, et al. countered that they had demanded compliance with the Compromise Agreement. On October 25, 2004, the PARAD ruled in favor of the Ampatuan Spouses, ordering the Lamirez Spouses, et al. to cease cultivation and vacate the land, finding them obligated as tenants to pay lease rentals until the land was placed under CARP. This decision was affirmed by the Department of Agrarian Reform Adjudication Board (DARAB) Central Office on February 22, 2007. A Petition for Certiorari was denied by the Court of Appeals, and the decision became final and executory on November 11, 2009.
On November 12, 2010, the Heirs of the Lamirez Spouses, et al. filed a Complaint for specific performance or damages before the Regional Trial Court (RTC), seeking enforcement of the Compromise Agreement. The Ampatuan Spouses raised the defense of res judicata. The RTC dismissed the complaint on August 2, 2012, on the ground of res judicata. The Court of Appeals affirmed this dismissal in its Decision dated January 15, 2016, holding that the final DARAB decision had already determined the parties’ rights and that the Heirs had raised the issue of specific performance in their counterclaim in the prior case, which was resolved against them.

ISSUE

Whether or not the Court of Appeals erred in holding that the action for specific performance to enforce the Compromise Agreement was barred by res judicata due to the final and executory decision of the Department of Agrarian Reform Adjudication Board.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the appellate court’s decision. The doctrine of res judicata applies. The elements of res judicata are present: (1) the former judgment must be final; (2) it must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) it must be a judgment on the merits; and (4) there must be, between the first and second actions, identity of parties, subject matter, and causes of action.
The DARAB decision had become final and executory. The DARAB, as a quasi-judicial agency, had jurisdiction over the agrarian dispute, which included the tenurial relations and rights arising from the Compromise Agreement. There is identity of parties (the Heirs are the successors-in-interest of the original parties) and identity of subject matter (the disputed agricultural land). Crucially, there is identity of causes of action. The cause of action in both the DARAB case (where the Heirs raised non-compliance with the Compromise Agreement as a defense and counterclaim) and the RTC case for specific performance is fundamentally the same: the enforcement of rights and obligations under the Compromise Agreement. The Heirs’ claim for specific performance was already raised and necessarily resolved in the prior agrarian case. The DARAB’s ruling that the Heirs failed to fulfill their tenurial obligations (paying rentals) and were thus not entitled to remain on the land implicitly carried a determination that they could not demand performance from the Ampatuan Spouses under the agreement. Therefore, the final DARAB judgment bars the subsequent action for specific performance.