G.R. No. L-57351. January 16, 1982.
MACARIO FESTIN, BENJAMIN FAMILARA, CARLITO FETALCURIN, GALICANA FORMADERO, SEGUNDO FABABAIR, ROLLO FAINSAN, DAVID FETALVERO, FRANCISCO FORFIEDA, JOSE PAZ and CARLITO FONTE, petitioners, vs. JORY F. FADERANGA, NORBERTA RIOS, ANTOLIN FRUELDA, FILEMON MARTINQUILLA, AVELINO FABONAN, ERNESTO FERRANCULLO, ELMER FABAYOS, PEDRO FADEROGAO, REYNALDO FETALVERO, RADIGONDES FAMINI, respondents.

FACTS

This is a petition for quo warranto filed by Macario Festin and others against the respondents, who are the incumbent municipal officials of Banton, Romblon. The controversy originated from a pre-proclamation dispute concerning the 1980 local elections. The respondents (then petitioners) had earlier filed with the Commission on Elections a petition to disqualify the herein petitioners (then respondents) for allegedly changing party affiliation within six months before the election. The Comelec initially denied the disqualification petition, leading to the petitioners’ proclamation on March 3, 1980. However, upon motion for reconsideration, the Comelec reversed itself on December 29, 1980, disqualifying the petitioners. This Comelec reversal was elevated to the Supreme Court in G.R. No. 55938 (Faderanga v. Commission on Elections).
In that prior case, the Supreme Court, in a decision promulgated on June 26, 1981, set aside the Comelec’s disqualification order. The Court ruled that once a candidate is proclaimed, any pre-proclamation controversy is terminated. The proper subsequent remedies are an election protest or a quo warranto proceeding. The decision became final and executory, with entry of judgment on July 13, 1981. Despite this finality, the petitioners herein, who were the losing parties in G.R. No. 55938, filed the instant quo warranto petition directly with the Supreme Court.

ISSUE

Whether the instant petition for quo warranto is proper and meritorious in light of a prior final and executory Supreme Court decision involving the same parties and subject matter.

RULING

No. The petition is dismissed. The Supreme Court held that the filing of this quo warranto suit constitutes a blatant disregard of the doctrine of finality of judgment and is a transparent attempt to evade a conclusive ruling. The Court had already definitively resolved the core electoral dispute in G.R. No. 55938 (Faderanga v. Comelec). In that decision, the Court established that the pre-proclamation stage had ended with the petitioners’ proclamation on March 3, 1980. Consequently, the respondents’ sole recourse was to file either an election protest or a quo warranto petition in the proper court within the periods prescribed by law. The Supreme Court’s decision in that case was final and had long been entered in the Book of Entries of Judgments. The parties are conclusively bound by it.
The legal logic is clear: res judicata applies. A matter that has been adjudicated by a court of competent jurisdiction and has attained finality is immutable and unalterable. The instant petition, filed by the very parties bound by the prior judgment, seeks to relitigate the same fundamental issue—the right to hold the municipal offices—which was already settled. The Court emphasized that the proper quo warranto remedy contemplated in its Faderanga decision was one to be filed with the Court of First Instance (now Regional Trial Court) under the Election Code,