G.R. No. L-24559 July 22, 1981
J.M. TUASON & CO., INC., petitioner, vs. HON. GUILLERMO E. TORRES, Judge, of the Court of First Instance of Rizal, Branch VIII, FLORENCIO DEUDOR, ANIANA DEUDOR, PEDRO DEUDOR and MARIA DEUDOR, respondents.

FACTS

Petitioner J.M. Tuason & Co., Inc. is the registered owner of parcels of land in Quezon City. In 1953, a decision by the Court of First Instance of Rizal, based partly on a compromise agreement, declared the petitioner the absolute owner of the subject properties, with the respondent Deudors expressly renouncing any claim. This 1953 decision and compromise were upheld by the Supreme Court in Deudor vs. J.M. Tuason & Co., Inc. (G.R. No. L-13768, May 30, 1961). Subsequently, in 1962, the Deudors filed a complaint to annul the compromise agreement before the Manila CFI (Civil Case No. 49657), which was dismissed. The Supreme Court, in Deudor vs. J.M. Tuason & Co., Inc. (G.R. No. L-20105, October 31, 1963), sustained the dismissal, ruling the action was barred by the prior final judgment in G.R. No. L-13768.
Despite these two final Supreme Court decisions, the Deudors, assisted by the same counsel, filed a third action (Civil Case No. 8080) before the respondent Judge, seeking to annul the very same 1953 CFI decision over the same properties. The respondent court admitted the complaint and issued restraining orders. Various parties also filed complaints-in-intervention, alleging the petitioner’s title was void. J.M. Tuason & Co. filed this petition for certiorari and prohibition to challenge the respondent judge’s orders and to seek dismissal of Civil Case No. 8080.

ISSUE

Whether the respondent judge acted with grave abuse of discretion in taking cognizance of and proceeding with Civil Case No. 8080, which seeks to annul a final and executory judgment that has already been affirmed by the Supreme Court.

RULING

Yes. The Supreme Court granted the petition, annulled the assailed orders, and ordered the dismissal of Civil Case No. 8080. The ruling is anchored on the doctrine of res judicata, specifically “bar by prior judgment.” The 1953 CFI decision, as affirmed by the Supreme Court in G.R. No. L-13768, constitutes a final judgment on the merits regarding the ownership of the land and the validity of the Deudors’ quitclaim. The matter raised in Civil Case No. 8080—the annulment of that 1953 decision—is identical to the cause of action and subject matter already conclusively settled. The Supreme Court in G.R. No. L-20105 had already explicitly ruled that any further complaint on this matter was barred.
Therefore, the respondent judge committed a grave abuse of discretion in entertaining the new complaint, as he had a ministerial duty to dismiss it for being barred by res judicata. The complaints-in-intervention were likewise ordered dismissed. An intervention is merely ancillary to the main action; the dismissal of the principal case carries with it the dismissal of the interventions. Moreover, the intervenors’ claimed interest was predicated on the alleged nullity of the petitioner’s title, an issue already laid to rest by the final Supreme Court pronouncements upholding its validity.