G.R. No. L-29080 August 17, 1976
CONCEPCION MACABINGKIL, plaintiff-appellant, vs. PEOPLE’S HOMESITE AND HOUSING CORPORATION, and IRENE DE LEON and her husband, VICENTE LLANES, defendants-appellees.

FACTS

Petitioner Concepcion Macabingkil filed an action for specific performance to compel the People’s Homesite and Housing Corporation (PHHC) to execute a Deed of Conditional Contract to Sell a specific subdivision lot (Lot No. 27) in her favor. Her claim was based on a PHHC Board Resolution that re-awarded the lot to her. The spouses Irene de Leon and Vicente Llanes successfully moved to intervene, asserting that the same lot had already been validly sold to them by the PHHC under a Conditional Contract to Sell executed earlier. They further contended that the very PHHC Resolution relied upon by Macabingkil had already been declared null and void in a prior final judgment (Civil Case No. Q-5866, affirmed by the Court of Appeals), which upheld the De Leons’ contract and ordered the PHHC to eject squatters from the lot.
The trial court, after a preliminary hearing on affirmative defenses treated as a motion to dismiss, ordered the dismissal of Macabingkil’s complaint for failure to state a cause of action. It found that the prior final judgment had conclusively settled the rights over the property in favor of the De Leon spouses and nullified Macabingkil’s basis for claim. The Court of Appeals affirmed this dismissal. Macabingkil elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the trial court correctly dismissed Macabingkil’s complaint for failure to state a cause of action, based on the affirmative defenses of res judicata (bar by prior judgment) and conclusiveness of judgment.

RULING

Yes, the Supreme Court affirmed the dismissal. The legal logic rests squarely on the doctrine of res judicata, specifically “conclusiveness of judgment.” A final judgment on the merits rendered by a court of competent jurisdiction is conclusive on the parties and their privies regarding all matters directly adjudged or necessarily implied therein. The prior case (De Leon vs. PHHC) involved the same parties or their privies and the same subject matter—the ownership and right to purchase Lot No. 27. In that case, the court definitively ruled that PHHC Resolution No. 550 (Macabingkil’s basis for claim) was null and void, and it upheld as valid and binding the Conditional Contract to Sell executed in favor of the De Leon spouses.
This prior judgment is binding not only on the PHHC but also on Macabingkil. As the party claiming under the same PHHC resolution that was annulled, she is in privity with the PHHC regarding that particular issue. Therefore, she is barred from re-litigating the validity of that resolution or asserting any right derived from it. Her present action, which seeks to enforce a right based on that void resolution, necessarily fails as it has no legal foundation. The Court also noted that Macabingkil had previously acquiesced to a compromise where she accepted a different lot, thus repudiating her claim to Lot No. 27. Consequently, the complaint correctly failed to state a cause of action, warranting its dismissal.