G.R. No. and Date: G.R. No. L-10080, November 3, 1917
Case Title: ENRIQUE M. BARRETTO, plaintiff-appellant, vs. TOMAS CABAÑGIS, defendant-appellee.

FACTS:
The plaintiff, Enrique M. Barretto, filed an action to recover possession of a parcel of land in Manila and to claim damages. The defendant, Tomas Cabañgis, raised the defense of res judicata, asserting that the ownership of the same land had already been litigated and conclusively decided in a prior case (Civil Case No. 3073, Court of First Instance of Manila, which reached the Supreme Court as G.R. No. 3983 ). In that prior case, the plaintiffs Salvadora Ocampo, Luis Abella, and Geronimo Abella (Barretto’s predecessors-in-interest) claimed ownership of the land, but the Supreme Court ultimately reversed the lower court’s judgment and absolved Cabañgis from the complaint.

Barretto purchased the land from Ocampo and the Abellas on December 29, 1909, three days after the Supreme Court’s decision in G.R. No. 3983 was promulgated but before it became final. Despite having full knowledge of the pending litigation, Barretto did not substitute himself as a party in the earlier case and allowed the proceedings to continue in the names of his vendors. The prior judgment became final on January 18, 1909. Barretto initiated the present action only in November 1911.

The defendant also raised the defense of acquisitive prescription, alleging that he and his predecessors had been in open, continuous, and adverse possession of the land for over fifty years.

ISSUE:
Whether the present action is barred by the principle of res judicata.

RULING:
Yes, the action is barred by res judicata. The Supreme Court affirmed the lower court’s judgment dismissing Barretto’s complaint.

The Court held that all elements of res judicata were present: (1) the prior judgment was final; (2) the court that rendered it had jurisdiction over the subject matter and parties; (3) it was a judgment on the merits; and (4) there was identity of parties, subject matter, and cause of action between the prior and present cases.

Barretto was the successor-in-interest of Ocampo and the Abellas, having purchased the land with full knowledge of the ongoing litigation and the adverse decision against his vendors. By failing to substitute himself in the prior case and by permitting the judgment to become final, he became bound by its outcome. The question of ownership of the land had already been conclusively settled against his predecessors, and he could not relitigate the same issue.

Given this disposition, the Court found it unnecessary to extensively discuss the alternative defense of prescription, though it noted that the evidence strongly supported the defendant’s claim of long-term, uninterrupted possession.

The judgment of the lower court was affirmed, with costs against the appellant.

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