G.R. No. L-19783 July 30, 1965
TECLA GARCIA, petitioner, vs. COURT OF APPEALS and PATRICIA DIMAUNAHAN, respondents.

FACTS

Hilarion Dimaunahan died on April 6, 1943, leaving his widow, Tecla Garcia, and four siblings: Clara, Romero, Agatona, and Patricia Dimaunahan. On August 17, 1945, Tecla Garcia instituted summary settlement proceedings for her husband’s estate in the Court of First Instance of Batangas (Case No. 3949). The court, on April 11, 1946, decreed one-half of the estate to the siblings, subject to the widow’s usufruct, and awarded the other half to Tecla Garcia as her conjugal share. Patricia Dimaunahan later initiated separate intestate proceedings (Case No. 4115), which were dismissed, and she was directed to intervene in Case No. 3949. In her opposition therein, Patricia claimed the estate was worth more and that Tecla Garcia had conveyed four parcels of land to her via a public instrument dated December 1, 1944, as part of her hereditary portion. After Patricia began presenting evidence, the trial was postponed. On December 22, 1949, the court dismissed Patricia’s opposition for lack of interest, revived its 1946 distribution order, and later approved Tecla’s project of partition, which allocated the disputed parcels differently (some to Tecla, some jointly to the siblings, and one for sale). Patricia’s attempts to set aside these orders failed, including an appeal to the Court of Appeals (CA- GR No. 7882 -R). Subsequently, Patricia filed an action for specific performance in the Court of First Instance of Manila (Case No. 20057) to compel Tecla to execute a deed of conveyance for the same four parcels based on the alleged 1944 affidavit. Tecla defended that the action was barred by the prior Batangas judgment. The Manila court dismissed the case on that ground, but the Court of Appeals reversed, prompting Tecla’s petition for review.

ISSUE

Whether the action for specific performance filed by Patricia Dimaunahan in the Court of First Instance of Manila is barred by res judicata due to the prior judgment in the summary settlement proceedings in the Court of First Instance of Batangas.

RULING

Yes, the action is barred by res judicata. The Supreme Court reversed the decision of the Court of Appeals and reinstated the dismissal by the Court of First Instance of Manila. All elements of res judicata are present: (1) the Batangas court had jurisdiction to decide Patricia’s claim to a greater portion of the estate; (2) there was a final judgment on the merits adverse to her claim, as her opposition was dismissed for lack of prosecution; (3) the parties are identical (Patricia Dimaunahan vs. Tecla Garcia); and (4) the causes of action are the same, as both cases relied on the same alleged affidavit to claim entitlement to the four parcels as part of her hereditary share, even though the Manila suit was framed as specific performance. The test of identity of causes of action is whether the same evidence would support both, which is incontrovertible here. The dismissal of Patricia’s opposition in the Batangas case, which became final, precludes relitigation of the same claim.