G.R. No. L-34425. January 28, 1980.
ALFONSO GATUS, petitioner, vs. HON. COURT OF APPEALS and ARSENIO MATIC, respondents.

FACTS

This is an ejectment case filed by agricultural lessor-owner Arsenio Matic against his agricultural lessee, Alfonso Gatus, over a parcel of riceland in Bulacan, on the ground of personal cultivation. The parties were previously involved in CAR Case No. 1500-Bulacan ’66, where Gatus sought to fix leasehold rentals. In that case, Matic interposed a counterclaim for ejectment on the same ground of personal cultivation. After trial, the Court of Agrarian Relations (CAR) fixed the rental but dismissed Matic’s counterclaim “without prejudice,” citing his failure to prove his ability to perform all phases of farm work.
Subsequently, Matic filed a new and separate complaint for ejectment, docketed as CAR Case No. 7, alleging he had performed all farm work on the land for twenty years prior to Gatus’s tenancy. Gatus moved to dismiss, arguing the cause was barred by a prior judgment (res judicata) and that the complaint stated no cause of action. The CAR trial court granted the motion, holding the new case sought a re-litigation of the same cause. The Court of Appeals reversed, ordering remand for further proceedings, reasoning that the right to demand personal cultivation is continuing and Matic should be allowed to prove changed circumstances.

ISSUE

Whether the principle of res judicata bars the subsequent ejectment case (CAR Case No. 7) filed by Matic against Gatus.

RULING

Yes, res judicata applies. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s order of dismissal. All elements of res judicata are present: (1) a prior final judgment in CAR Case No. 1500 dismissing Matic’s counterclaim for ejectment; (2) jurisdiction of the CAR over the subject matter and parties; (3) a judgment on the merits after trial; and (4) identity of parties, subject matter, and cause of action between the two cases.
The cause of action in both proceedings is identical: ejectment based on personal cultivation. The matter of Matic’s ability to personally cultivate was directly litigated and adjudged in the first case. The doctrine of estoppel by judgment prevents a party from re-litigating the same issue by presenting new arguments or evidence that could have been raised in the prior action, absent a change in the parties’ legal rights or relations. The Court held that the dismissal “without prejudice” of the counterclaim in the first case was a mere surplusage, as it cannot confer a right where the law, through res judicata, bars its assertion. Consequently, the subsequent action was properly dismissed. The Court found no need to resolve the ancillary issue regarding the retroactivity of Republic Act No. 6389, which deleted personal cultivation as a ground for ejectment.