G.R. No. 83828. November 16, 1989. LEONOR MAGDANGAL, ET AL., petitioners, vs. CITY OF OLONGAPO, DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES AND/OR DIRECTOR OF THE BUREAU OF LANDS, THE REGISTRY OF DEEDS OF OLONGAPO CITY and HON. SOLICITOR GENERAL, respondents.
FACTS

The petitioners, members of the Pag-asa Lot Owners Association, Inc., constructed dwellings on a parcel of land designated as Lot 21 within a National Park Reservation in Olongapo City. Their occupancy was challenged by the enactment of Batas Pambansa Blg. 875, which detached Lot 21 from the reservation and ceded its ownership and possession to the City of Olongapo for use as a cultural, trade, and tourism center. The law included a provision recognizing any acquired private rights and mandating compensation. The petitioners, asserting vested rights, sought to nullify the law.
This petition was not the first legal challenge mounted by the petitioners. In a prior case, G.R. No. 71362, entitled “Pag-asa Lot Owners Association, Inc., et al. v. The City Mayor of Olongapo and/or Olongapo City, et al.,” the same group of petitioners directly assailed the constitutionality of B.P. Blg. 875. The Supreme Court, in a Resolution dated October 9, 1985, dismissed that petition for lack of merit after considering its allegations and the respondents’ comment. The present petition for prohibition raises the identical constitutional challenge.

ISSUE

Whether the present petition for prohibition, which assails the constitutionality of Batas Pambansa Blg. 875, is barred by the doctrine of res judicata due to the prior final dismissal in G.R. No. 71362.

RULING

Yes, the petition is barred by res judicata. The Court applied the settled rule that a final judgment on the merits by a court with jurisdiction is conclusive in a subsequent case involving the same parties, subject matter, and cause of action. All requisites for res judicata are present. First, the judgment in G.R. No. 71362 dismissing the petition for lack of merit had long become final. Second, the Supreme Court unquestionably had jurisdiction over the constitutional issue and the parties. Third, a dismissal for lack of merit, even via a minute resolution, constitutes a judgment on the merits, as established in Sy v. Tuvera.
Finally, there is identity of parties, subject matter, and cause of action. The petitioners in both cases are substantially identical, being members of the same association. The subject matter in both is the constitutionality of B.P. Blg. 875. While the form of action differs—the prior being for declaratory relief and the present for prohibition—the fundamental cause of action is identical: the assertion that the law impairs contractual obligations and constitutes a deprivation of property without due process. The Court, citing Ibabao v. IAC, held that a party cannot escape res judicata by merely varying the form of action. Since the constitutional issue was squarely raised and adjudicated with finality in G.R. No. 71362, the present action is barred. The petition was dismissed.