G.R. No. L-26986 September 30, 1977
Carmen Ramos, plaintiff-appellant, vs. Pangasinan Transportation Co., Inc. and Romeo Ferrer, defendants-appellees.
FACTS
Carmen Ramos initially filed a damages suit (Civil Case No. D-705) against Pangasinan Transportation Co. (Pantranco) and its driver, Romeo Ferrer, for injuries sustained in a bus accident. While the case was pending, the parties executed a “Compromise and Quitclaim” agreement on January 8, 1959. Ramos acknowledged receipt of P1,180.00 and, in consideration, released Pantranco and Ferrer from all claims arising from the accident. She subsequently filed a “Motion for Definite Dismissal,” stating the parties had amicably settled. The trial court granted the motion and dismissed the case.
On January 2, 1961, Ramos filed a new complaint (Civil Case No. D-1155) against the same defendants, seeking damages for the same accident. She alleged the Compromise and Quitclaim was procured through fraud, deceit, or misrepresentation and prayed for its annulment. The defendants moved to dismiss the new complaint on the ground of res judicata. The trial court granted the motion, ruling that the dismissal of the first case upon Ramos’s own motion was an adjudication on the merits that barred the second suit.
ISSUE
Whether the second action (Civil Case No. D-1155) is barred by the principle of res judicata.
RULING
Yes, the second action is barred by res judicata. The Supreme Court affirmed the trial court’s order of dismissal. For res judicata to apply, three identities must be present: identity of parties, subject matter, and cause of action. All three were satisfied. The parties in both suits were identical. The subject matter concerned the same accident and the injuries Ramos allegedly suffered. The cause of action in both cases was fundamentally the same: a claim for damages arising from the accident.
The Court emphasized that the dismissal of the first case upon Ramos’s own “Motion for Definite Dismissal,” which the court granted, constituted a final judgment on the merits. The fact that Ramos later attempted to repudiate the compromise by filing an “Urgent Motion to Lift Order of Dismissal” in the first case, wherein she raised the issue of fraud, was of no consequence. That motion was denied by the trial court for lack of merit, and Ramos failed to perfect a timely appeal from that denial. That order became final and binding. She cannot now resurrect the same issue of fraud, which she had already litigated and lost, by filing a new complaint. A party cannot escape the operation of res judicata by merely varying the form of the action or adding new allegations when the fundamental cause of action remains the same. The policy against multiplicity of suits demands that matters once settled by final judgment should not be relitigated.