G.R. No. 230687. December 05, 2018
ERLINDA S. IGOT, PETITIONER, v. PIO VALENZONA, FRANCISCO VALENZONA NUÑEZ, KATHERINE VALENZONA RAMIREZ, ALL REPRESENTED BY ARTURO VALENZONA THROUGH POWERS OF ATTORNEY, AND SPS. ARTURO AND AIDA VALENZONA, RESPONDENTS.

FACTS

Respondents, heirs of spouses Julian and Sotera Valenzona, filed a complaint for recovery of possession, ownership, and quieting of title against petitioner Erlinda S. Igot and her mother, Elena Santome. They claimed ownership over Cadastral Lot No. 286, alleging their predecessors’ possession for over 50 years. Petitioner and Elena countered that the property was bought by Elena’s father, Gorgonio Santome, from Julian in 1929. They relied on a prior 1998 case (Civil Case No. 418) filed by Elena against one heir, Agapito Valenzona, where the MTC declared Elena the lawful owner and ordered Agapito to vacate. That decision became final after Agapito failed to appeal. Based on this, Elena obtained a tax declaration and later sold the property to petitioner.

ISSUE

Whether the final and executory judgment in Civil Case No. 418, which declared Elena Santome the owner of the subject property, constitutes res judicata and conclusively settles the issue of ownership in the present case.

RULING

Yes. The Supreme Court ruled that the doctrine of res judicata applies, barring the re-litigation of the issue of ownership. For res judicata by conclusiveness of judgment to apply, the following must concur: (1) the former judgment must be final; (2) it must have been rendered by a court having jurisdiction; (3) it must be a judgment on the merits; and (4) there must be identity of parties, subject matter, and causes of action between the first and second actions. All these elements are present. The MTC decision in Civil Case No. 418 was a final judgment on the merits. The MTC had jurisdiction as the assessed value of the property was within its jurisdictional limit. While the present respondents were not all named parties in the first case, they are in privity with the defendant, Agapito Valenzona, as co-heirs claiming rights from the same predecessor, Julian Valenzona. Privity of interest exists, making them bound by the prior adverse judgment. The subject matter and cause of action (recovery of ownership and possession based on the 1929 alleged sale) are identical. Therefore, the prior judgment is conclusive on the issue of ownership. The Court reversed the Court of Appeals and reinstated the RTC decision, which had dismissed the respondents’ complaint, with modification on interest.