G.R. No. L-16002, May 23, 1961
LUIS SARABIA AND JOSE LEIDO, petitioners-appellants, vs. THE SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, THE DIRECTOR OF FISHERIES and FRANCISCO B. LARDIZABAL, respondents-appellees.

FACTS

Petitioners Luis Sarabia and Jose Leido filed fishpond applications in 1951, followed by respondent Francisco Lardizabal in 1952. Initially, the applied-for land was part of a communal forest and unavailable. After the area was disestablished and certified as available in 1953, the Director of Fisheries granted portions to Sarabia and Leido, rejecting Lardizabal’s application due to the petitioners’ prior filing preference under fisheries regulations. Lardizabal protested to the President via the PCAC. The Secretary of Agriculture and Natural Resources, treating this as an appeal, modified the Director’s order in 1955, reducing the areas granted to Sarabia and Leido and allocating a portion to Lardizabal.
Petitioners Sarabia and Leido first challenged this 1955 order via a petition for certiorari in the Court of First Instance (CFI) of Manila, arguing the Secretary acted without jurisdiction as Lardizabal’s appeal was filed out of time. The CFI dismissed the petition, ruling certiorari was improper as appeal was the correct remedy, and the petitioners had failed to exhaust administrative remedies. Their appeal to the Supreme Court was dismissed for being filed out of time. Subsequently, petitioners filed a new petition, this time for prohibition, in the CFI, again seeking to nullify the same 1955 order on identical jurisdictional grounds.

ISSUE

Whether the present petition for prohibition is barred by the doctrine of res judicata due to the prior final judgment in the certiorari case.

RULING

Yes, the petition is barred by res judicata. The Supreme Court affirmed the dismissal of the prohibition petition. The legal logic is clear: for res judicata to apply, there must be (1) a final former judgment, (2) rendered by a court with jurisdiction, (3) on the merits of the case, and (4) identity of parties, subject matter, and cause of action between the first and second cases. All these elements are present. The CFI’s dismissal of the prior certiorari petition constituted a final judgment on the merits, as it was based on petitioners’ lack of a cause of action for choosing the wrong remedy and failing to exhaust administrative avenues, not on a lack of court jurisdiction. Their failed appeal solidified this finality.
Crucially, the cause of action in both petitions is identical: the alleged nullity of the Secretary’s 1955 order based on the untimeliness of Lardizabal’s appeal. The parties are the same. The mere shift in the form of action from certiorari to prohibition does not create a new cause of action when the fundamental grievance and the relief sought (annulment of the order) remain unchanged. The incidental prayer for an injunction in the prohibition case is dependent on the same core issue. The doctrine of res judicata rests on the paramount policy of preventing repetitive litigation over the same settled issues. Having fully and fairly pursued their challenge to the administrative order in the first case, petitioners are conclusively bound by its outcome and cannot resurrect the same dispute under a different procedural label.