GR L 20073; (October 1975) (Digest)
G.R. No. L-20073 October 3, 1975
ISABELO SENORO, TEODORICO SENORO and ESTELITO SENORO, plaintiffs-appellants, vs. FRANCISCO LOBO, GILDA LOBO, SANTIAGO LOBO, SOCORRO SOLDEVILLA, ESPERIDION LOBO, AGRIPINA LABANSAWAN, JOSE LABANSAWAN, FELIPE LABANSAWAN, ZOILA LABANSAWAN, ERIBERTO INFANTE, FRANCISCO INFANTE and JESUSA INFANTE, defendants-appellees.
FACTS
The plaintiffs-appellants, the Senoros, filed a complaint for reconveyance or monetary compensation regarding Lot No. 1687-B, claiming inheritance rights as heirs of Juan Lobo. They alleged that the property, originally owned by Juan Lobo, was erroneously titled in the name of the “Heirs of Juan Labansawan” following a free patent application, and that the defendants had taken exclusive possession. The defendants-appellees Labansawans and Infantes moved to dismiss the complaint on the ground of res judicata, citing a prior final judgment.
The prior case, Civil Case No. 2435, was filed by the Labansawans and Infantes against the Senoros and others to annul the Senoros’ title to the same lot, alleging it was secured through a fraudulent declaration of ownership. The trial court declared the Senoros’ title null and void, ordered the issuance of a new title in favor of the Labansawans and Infantes, and awarded damages. This judgment was affirmed by the Court of Appeals. The trial court in the present case granted the motion to dismiss, ruling the Senoros’ new action was barred by this prior judgment.
ISSUE
Whether the complaint filed by the Senoros is barred by the principle of res judicata.
RULING
Yes, the complaint is barred by res judicata. The Supreme Court affirmed the order of dismissal. For res judicata to apply, there must be: (1) a final former judgment; (2) a court of competent jurisdiction; (3) a judgment on the merits; and (4) identity of parties, subject matter, and causes of action between the first and second actions. All these elements are present.
The judgment in Civil Case No. 2435 was a final judgment on the merits rendered by a court of competent jurisdiction. There is identity of subject matter, as both cases concern the ownership and possession of the same Lot No. 1687-B. There is also identity of causes of action. The Court explained that the doctrine is concerned with the substance of the litigation, not merely the form of the action. Although the present complaint is styled as one for reconveyance with alternative prayers for damages, its fundamental objective—to recover ownership and possession of the lot—is identical to the objective of the prior annulment case. The alternative reliefs sought do not create a new cause of action.
The appellants’ argument that there is no identity of parties due to the inclusion of new defendants is untenable. The critical point is that the plaintiffs-appellants here (the Senoros) were the defendants against whom the prior judgment was rendered. The joinder of additional parties in the second action does not defeat the application of res judicata against a party who was present in the first suit; otherwise, litigation could be endlessly renewed by simply adding new parties. The prior case definitively resolved that the lot was owned by the heirs of Juan Labansawan, not the heirs of Juan Lobo. Therefore, the Senoros’ present action is barred.