G.R. No. L-42230 November 26, 1986
LAURO IMMACULATA, represented by his wife AMPARO VELASCO as Guardian Ad Litem, petitioner, vs. HON. PEDRO C. NAVARRO, in his capacity as Presiding Judge of the Court of First Instance of Rizal, Branch No. II, and HEIRS OF JUANITO VICTORIA, namely: LOLITA, TOMAS, BENJAMIN, VIRGINIA, BRENDA AND ELVIE, all surnamed RIA, and JUANITA NAVAL, surviving widow; and the PROVINCIAL SHERIFF OF RIZAL, respondents.

FACTS

Petitioner Lauro Immaculata, represented by his wife as guardian ad litem, filed a complaint (Civil Case No. 20968) seeking the annulment of a judgment from a prior case (Civil Case No. 13734) and a deed of absolute sale over a parcel of land. He alleged that in 1969, Juanito Victoria, through deceit and by taking advantage of his mental illness, caused him to execute a simulated deed of sale. Based on this deed, Victoria filed an action for specific performance. Immaculata claimed he was not validly served summons in that prior case, was declared in default, and a judgment by default was rendered against him, leading to the issuance of a new title in Victoria’s name.
The respondents moved to dismiss the new complaint on grounds of lack of jurisdiction, failure to state a cause of action, and res judicata. The trial court, presided by respondent Judge Pedro C. Navarro, dismissed the case solely on the ground of res judicata. It ruled that the issues raised in the new complaint had already been the subject matter of the final decision in the prior specific performance case. Immaculata’s motion for reconsideration was denied, prompting this petition for review on certiorari.

ISSUE

Whether the trial court correctly dismissed the complaint for annulment of judgment and deed of sale on the ground of res judicata.

RULING

Yes, the Supreme Court upheld the dismissal. The Court explained that for res judicata to apply, four requisites must concur: (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 cause of action between the first and second cases. All these requisites were present. The judgment in Civil Case No. 13734 for specific performance had become final and executory. The court that rendered it had jurisdiction. The decision was on the merits, as it ordered Immaculata to deliver the title and execute documents to effect the sale’s registration, which necessarily entailed a ruling on the validity of the sale contract itself.
The Court found identity of parties (Immaculata and Victoria/heirs) and subject matter (the same parcel of land). While the causes of action were nominally different—specific performance versus annulment—the core issue of the sale’s validity due to fraud and incapacity was already inherent and could have been raised as a defense in the first case. The Court noted that Immaculata had previously filed a petition to set aside the default judgment in the first case, raising the same issues, which was denied. Therefore, the principle of res judicata bars the re-litigation of these settled issues. The petition was denied.