GR L 62341; (October, 1988) (Digest)
G.R. No. L-62341. October 28, 1988.
JORGE WEE SIT and LUCIA WEE SIT, petitioners, vs. HON. OMAR U. AMIN, District Judge, Court of First Instance, Zamboanga City, JESUS AQUINO and CARMEN BENITO, respondents.
FACTS
The dispute originated from a 1976 Amended Compromise Agreement approved by the Court of First Instance in Special Case No. 21, settling the claim of respondent Atty. Jesus Aquino against the estate of Juan S. Wee Sit. The agreement ceded Lot 651-A to Aquino via dacion en pago. It granted petitioner Lucia Wee Sit a lifetime right to occupy the house on the lot rent-free, with the right to remove the house materials upon vacating. After the two-year grace period, Aquino filed an ejectment case against Jorge Wee Sit, which was decided in Aquino’s favor and became final after the Supreme Court denied review. Subsequently, the Wee Sits filed a separate complaint (Civil Case No. 2300) seeking to recover the lot, but it was dismissed on grounds of res judicata, a dismissal affirmed by the Supreme Court in G.R. No. 56112. Undeterred, the petitioners filed the present action (Civil Case No. 2701) for quieting of title, asserting ownership of the house itself despite Aquino’s ownership of the lot. The trial court dismissed this amended complaint, ruling the cause was barred by prior judgments.
ISSUE
Whether the trial court correctly dismissed the complaint for quieting of title on the ground of res judicata.
RULING
Yes, the dismissal was correct. The Supreme Court affirmed the application of res judicata, finding all its requisites present. First, there were two prior final judgments on the merits by courts of competent jurisdiction: the ejectment judgment ordering the petitioners to vacate and the judgment in Civil Case No. 2300 dismissing their recovery action, which sustained the validity of the compromise agreement. Second, there was identity of subject matter, concerning the same Lot 651-A and the house thereon. Third, there was identity of parties between the Wee Sit heirs and the spouses Aquino. Fourth, there was identity of cause of action, as the present claim over the house ownership is fundamentally anchored on the same factual and legal basis—the interpretation of the 1976 compromise agreement—that was conclusively settled in the prior cases. The Court held the terms of the approved agreement were clear: ownership of both lot and house was ceded to Aquino, with Lucia Wee Sit granted merely a personal right of occupancy. The petitioners’ attempt to relitigate the ownership of the house was a direct collateral attack on the final compromise judgment. Consequently, the petition was dismissed for being barred by res judicata, and the petitioners were ordered to vacate the premises immediately.
