G.R. No. L-61752 September 28, 1984
SY KAO and CHUA LIAN KING, petitioners, vs. HON. COURT OF APPEALS, HON. JOSE P. CASTRO, Presiding Judge of the Court of First Instance of Rizal, Branch IX, (Quezon City) and CHUA KENG GIAP, respondents.

FACTS

Petitioners Sy Kao and Chua Lian King, widow and son of the late Chua Bing Guan, executed an extrajudicial settlement of his estate in 1967. In 1968, private respondent Chua Keng Giap filed a petition for the settlement of the same intestate estate (Special Proceedings No. Q-12592), claiming to be a son of the deceased. After a ten-year hearing, the court dismissed his petition on March 2, 1979, finding he was not a son of the deceased and thus had no interest in the estate. The respondent’s subsequent appeals, including a petition to the Supreme Court (G.R. No. 54992), were all dismissed.
Meanwhile, on July 14, 1980, the respondent filed a separate civil complaint against the petitioners seeking to annul their extrajudicial settlement, alleging he was a preterited heir and that the deceased had left a will acknowledging him. The petitioners moved to dismiss the complaint on grounds including res judicata, arguing the issue of filiation had been conclusively settled in the prior special proceedings. The trial court denied their motion, a decision affirmed by the Court of Appeals, prompting this petition.

ISSUE

Whether the civil complaint filed by the respondent is barred by the doctrine of res judicata due to the final judgment in the prior special proceedings.

RULING

Yes, the complaint is barred by res judicata. The Supreme Court reversed the lower courts and ordered the dismissal of the civil case. The doctrine of res judicata, under Section 49, Rule 39 of the Rules of Court, requires: (1) identity of parties or interests; (2) identity of rights asserted and reliefs founded on the same facts; and (3) a prior final judgment on the merits. All elements are present. The parties in both the prior special proceedings and the subsequent civil case are the same, litigating in their identical capacities as alleged heirs of the deceased. The right asserted by the respondent in both actions is his claim of being a son of Chua Bing Guan to inherit from the estate. The prior case conclusively adjudicated this very issue against him, resulting in a final judgment that remains unreversed. Allowing the new complaint would compel the petitioners to relitigate the same factual issue for over a decade, violating the public policy against multiplicity of suits. The existence of a separate probate proceeding for an alleged will does not affect this conclusion, as the core issue of filiation has already been definitively resolved.