G.R. No. 97929 October 22, 1993
LEONIDA LANTICAN and JOSELITO DE LA PENA, petitioners, vs. THE HONORABLE COURT OF APPEALS, SIXTH DIVISION, DURANTE L. UBEDA and GAUDENCIA MERCADO VDA. DE LA PENA, respondents.

FACTS

Marcos de la Pena died on February 25, 1986, leaving his legitimate wife, respondent Gaudencia Mercado, and daughter, Camila de la Pena, and his common-law wife, petitioner Leonida Lantican, and their children, including co-petitioner Joselito de la Pena. He was a tenant on a riceland owned by Rufina Lim and was about to be issued a Certificate of Land Transfer (CLT). Rufina Lim chose Gaudencia Mercado as the successor tenant. Petitioners opposed this. The Department of Agrarian Reform (DAR), through Minister Heherson Alvarez, issued an order on May 13, 1986, ruling that Gaudencia Mercado had the sole right to be the CLT beneficiary. Petitioners filed a motion to set aside this order, which was dismissed. Their motion for reconsideration was also denied by the DAR. Their recourse to the Office of the President resulted in a decision affirming the DAR orders. Petitioners then filed a petition for certiorari and prohibition with the Supreme Court (G.R. No. 83925), questioning the DAR’s jurisdiction. The Supreme Court dismissed that petition on January 30, 1989, for failure to show grave abuse of discretion and noted that petitioners had invoked the DAR’s jurisdiction in their motions for reconsideration. Subsequently, petitioners filed a petition for prohibition with the Regional Trial Court (RTC) of Laguna (SP Case No. 1364-89) seeking to annul the DAR order and restrain its enforcement. The RTC dismissed the petition, and the Court of Appeals affirmed the dismissal on the ground of res judicata, citing the final judgment in G.R. No. 83925.

ISSUE

Whether the petition for prohibition filed before the RTC is barred by res judicata due to the Supreme Court’s prior dismissal of G.R. No. 83925.

RULING

Yes, the petition is barred by res judicata. The Supreme Court affirmed the decision of the Court of Appeals. The issue regarding the jurisdiction of the DAR had already been settled in G.R. No. 83925, where the Court dismissed the petition and, in effect, affirmed the DAR’s jurisdiction. The Court ruled that all essential elements of res judicata were present: a final judgment on the merits (the Supreme Court’s resolution in G.R. No. 83925), rendered by a court of competent jurisdiction, between the same parties, and involving the same cause of action. The Court further held that petitioners were estopped from assailing the DAR’s jurisdiction because they had actively participated in the DAR proceedings by filing motions for reconsideration and seeking affirmative relief. The filing of the subsequent petition for prohibition with the RTC was an attempt to circumvent the final resolution of the Supreme Court and to delay the execution of the DAR’s decision. The petition was denied for lack of merit.