G.R. No. L-37312 July 15, 1975
MARCOS B. COMILANG, petitioner, vs. THE HONORABLE COURT OF APPEALS, ABDON DELENELA, GUILLERMO PEREZ, DOMINGA COMILANG and ESTEBAN COMILANG, respondents.

FACTS

The dispute involves surface rights over the “Bua Fraction Mineral Claim” in Benguet. In a prior Supreme Court case, G.R. No. L-24757 (Marcos Comilang vs. Generoso A. Buendia, et al.), the Court ruled that respondents Abdon Delenela and Guillermo Perez were the absolute owners of the surface ground of the property. This decision stemmed from a complex history where a 1.5-hectare portion occupied by petitioner Marcos Comilang was sold at a sheriff’s auction to satisfy a judgment debt. Delenela and Perez later redeemed this property from the auction purchasers. Following this redemption, they obtained a writ of possession to evict Comilang, leading to the prior litigation that reached the Supreme Court.
Subsequent to that final Supreme Court ruling, Marcos Comilang initiated a new action in the lower court (Civil Case No. 848) seeking partition of the same property. The Court of Appeals, reviewing the lower court’s decision in favor of partition, set it aside. The appellate court held that the Supreme Court’s prior decision in G.R. No. L-24757, which definitively settled ownership of the surface rights in favor of Delenela and Perez, constituted res judicata and barred the new partition suit.

ISSUE

Whether the Court of Appeals correctly applied the principle of res judicata to dismiss the partition case based on a prior final Supreme Court decision involving the same property and parties.

RULING

Yes, the Supreme Court affirmed the Court of Appeals. The doctrine of res judicata, or “bar by prior judgment,” applies when there is a final judgment on the merits rendered by a court of competent jurisdiction, and the identity of parties, subject matter, and cause of action exists between the prior and subsequent cases. Here, the Supreme Court’s decision in G.R. No. L-24757 was a final adjudication on the merits regarding the ownership of the surface ground. That case conclusively determined Delenela and Perez as the absolute owners, thereby extinguishing any claim of co-ownership or right to partition by Marcos Comilang over the same property. The subsequent action for partition filed by Comilang presented the same fundamental issue of rights over the property already definitively resolved. The Court emphasized that a final Supreme Court decision constitutes the law of the case and is binding on all inferior courts, which are beyond their authority to alter or modify. Therefore, the Court of Appeals correctly ruled that the partition suit was barred by res judicata, as it sought to relitigate a matter already settled with finality.