GR L 62136; (February, 1985) (Digest)
G.R. No. L-62136 February 28, 1985
ZANSIBARIAN RESIDENTS ASSOCIATION FOR AND IN BEHALF OF ITS MEMBERS, petitioner, vs. THE MUNICIPALITY OF MAKATI, THE NATIONAL HOUSING AUTHORITY AND THE HUMAN SETTLEMENTS REGULATORY COMMISSION, respondents.
FACTS
The petitioner, Zansibarian Residents Association, filed a petition for prohibition and mandamus with a prayer for a temporary restraining order and preliminary injunction. The association, composed of members occupying land in Barangay San Isidro, Makati, sought to prevent the respondents from subdividing and distributing the land to others, to have its members restored to possession with their houses rebuilt, and to have the land permanently subdivided and awarded to them. They invoked Presidential Decree No. 1517 (the Urban Land Reform Law), claiming protection from ejectment. The Supreme Court initially issued a temporary restraining order.
However, the record revealed this was not the first action filed by the occupants. In 1978, a similar group filed an injunction case (Civil Case No. 31141) to stop the demolition of their houses, which was dismissed with prejudice in 1980 by the Court of First Instance of Rizal, Branch XV, on the ground that the plaintiffs had no color of title. In 1980, another complaint for injunction (Civil Case No. 38811) was filed and was dismissed in 1982 on the ground of res judicata, the court finding identity of parties, subject matter, and cause of action with the first dismissed case.
ISSUE
The primary issue is whether the present petition is barred by the prior judgments in the two earlier injunction cases.
RULING
The Supreme Court dismissed the petition. The legal logic is twofold. First, the petitioner’s members are not entitled to the protection of P.D. No. 1517. Section 6 of the decree protects only “legitimate tenants” or those who “legally occupied the land by contract.” The Court found the occupants were neither legitimate tenants nor legal occupants by contract. Furthermore, the Municipality of Makati had authority to demolish the structures under P.D. No. 772 and Letter of Instruction No. 19, which mandate the removal of illegal constructions.
Second, and decisively, the principle of res judicata bars the present action. For res judicata to apply, there must be a prior final judgment on the merits, rendered by a court of competent jurisdiction, and there must be identity of parties, subject matter, and cause of action between the first and second cases. The Court found all these elements present. The two prior injunction cases involved the same occupants (parties), the same parcel of land (subject matter), and the same objective of preventing their ejectment and the demolition of their houses (cause of action). The inclusion of additional government agency respondents in the present petition does not negate the identity of parties for the purpose of res judicata. The dismissals of the prior cases were final and constituted an absolute bar to relitigating the same claim. The Court emphasized the necessity of ending litigation to ensure effective administration of justice. Consequently, the petition was dismissed and the temporary restraining order was lifted.