G.R. No. L-26523, December 24, 1971
PELAGIO YUSINGCO, ET AL., plaintiffs-appellants, vs. ONG HING LIAN, ET AL., defendants-appellees.

FACTS

The plaintiffs-appellants, heirs of Alfonso Yusingco, filed a civil action for recovery of ownership (reivindicacion) over several parcels of land. This case was dismissed by the trial court on the ground of res judicata, barring the present suit due to a prior final judgment. The prior case was a petition for judicial reconstitution of titles under Republic Act No. 26 filed solely by Pelagio Yusingco, one of the heirs. In that reconstitution case, Pelagio alleged the lots were owned by the partnership “Alfonso Yusingco Hermanos,” composed of the heirs, and sought titles in the heirs’ names. The petition was opposed by the appellees, who claimed ownership as successors of Ong Bonpin. After protracted proceedings, including remands for reception of evidence, the Court of Appeals ultimately affirmed the denial of the reconstitution petition, finding that Ong Bonpin and his heirs had possessed the lots in the concept of owners.
The appellants argued that the dismissal of the present recovery suit was erroneous because the prior reconstitution case did not constitute res judicata. They contended that the reconstitution case was a special proceeding in rem, not an action to settle title, and that the parties were not identical since the earlier case was prosecuted only by Pelagio Yusingco in his personal capacity, not as a representative of all his co-heirs. They emphasized that the other heirs were not formally made parties to the prior case.

ISSUE

Whether the principle of res judicata bars the civil action for recovery of ownership filed by all the Yusingco heirs, based on the prior final judgment in the reconstitution case filed only by Pelagio Yusingco.

RULING

No, res judicata does not bar the action for the other plaintiffs-appellants, but it does bar Pelagio Yusingco individually. For res judicata to apply, there must be, among other elements, identity of parties and identity of causes of action between the prior and subsequent cases. The Court ruled that the requisite identity of parties was lacking for the co-heirs of Pelagio Yusingco. The prior reconstitution case was filed and prosecuted by Pelagio Yusingco alone. The record did not show that he instituted the case as a representative of his co-heirs or that they authorized him to litigate on their behalf. Consequently, the judgment in the reconstitution case bound only Pelagio Yusingco as a party-litigant. His co-heirs, not being parties to that case, cannot be precluded from asserting their own claims in a separate action. However, the principle of conclusiveness of judgment applies to Pelagio Yusingco himself. The factual findings and conclusions of the Court of Appeals in the reconstitution case—specifically, the determination that Ong Bonpin and his heirs were the lawful owners and possessors—are final and binding upon him, barring his re-litigation of the ownership issue. Thus, the trial court’s order of dismissal was affirmed with respect to appellant Pelagio Yusingco but set aside with respect to his co-heir plaintiffs-appellants, to whom the case was remanded for further proceedings.