RES JUDICATA
Sultan of the Regional Trial Court of Biñan, Laguna issued
G.R. No. 150470. August 6, 2008
Petitioners: SPOUSES FELIPE and VICTORIA LAYOS
Respondent: FIL-ESTATE GOLF AND DEVELOPMENT, INC.
FACTS:
The Injunction Cases:
G.R. No. 120958: Fil-Estate Golf and Development, Inc. v. Court of Appeals
The said case arose from the following facts:
Petitioner Fil-Estate Golf & Development, Inc. (FEGDI) is the developer of the Manila
Southwoods golf course and residential subdivision project which partly covers lands
located in Biñan, Laguna. Its partner in the joint venture, La Paz Housing and
Development Corporation (La Paz), provided the aforementioned properties which
are registered in its name.
On 29 December 1992, a certain Felipe Layos filed a complaint for Injunction and
Damages with Application for Preliminary Injunction against Fil-Estate Realty
Corporation, (FERC) et al. with the Regional Trial Court of Biñan, Laguna. It was alleged
in the said complaint that Felipe Layos is the legal owner and possessor of two (2)
parcels of land. Layos claimed that the Southwoods project encroached upon the
aforecited lands and thus contended that his rights of ownership and possession were
violated when FERC brought in men and equipment to begin development of the said
properties.
FEGDI filed an Answer to the abovementioned complaint and reiterated that the land
covered by the project is covered by Transfer Certificates of Title in the name of La
Paz. Presiding Judge Justo M.
an order denying the prayer for preliminary injunction in view of the inability of Layos
to substantiate his right.
On 25 June 1993, Felipe Layos along with his wife and other individuals filed another
case for Injunction and Damages with Prayer for Preliminary Injunction with the
Regional Trial Court of San Pedro, Laguna. FEGDI moved to dismiss the San Pedro case
on grounds of litis pendentia, forum-shopping, lack of cause of action and lack of
jurisdiction. Judge Stella Cabuco-Andres of the San Pedro Regional Trial Court issued
an order denying FEGDI's motion to dismiss.
FEGDI filed a Petition for Certiorari and Prohibition with Application for Preliminary
Injunction with the Court of Appeals. Thus, Court of Appeals issued a temporary
restraining order enjoining Judge Andres from proceeding with the San Pedro case.
Meanwhile, the Regional Trial Court of Biñan, Laguna dismissed the Biñan case
without prejudice on grounds of forum-shopping.
FEGDI moved for a partial reconsideration of the said order praying that the dismissal
be with prejudice. The Court of Appeals dismissed FEGDI's petition for lack of merit.
FEGDI's motion for reconsideration was subsequently denied.
FEGDI came to this Court via a Petition for Review on Certiorari. The Court granted
the Petition and ruled in favor of FEGDI.
The Court found that therein private respondents, which included the Spouses Layos,
did commit forum shopping by instituting similar proceedings for injunction before
the RTCs of Biñan and San Pedro, Laguna.
Consequently, on the grounds of forum shopping and lack of cause of action, the Court
decided in favor of the petitioner dismissing the San Pedro case.

G.R. No. 150470: The Reconstitution Case
The Court now comes to the Petition at bar.
The instant Petition originated from a Petition for Reconstitution filed by the Spouses
Layos with the San Pedro RTC, docketed as LRC Case No. B-1784.
FEGDI and La Paz filed separate Motions to Dismiss, which the Office of the Solicitor
General supported in its Comment on the Petition. The San Pedro RTC issued an Order
to dismiss the case.
The San Pedro RTC denied the Spouses Layos' Motion for Reconsideration. Spouses
Layos filed an appeal with the Court of Appeals. However, found no reversible error
in the ruling of the lower court dismissing the Spouses Layos' Petition for
Reconstitution
According to the Court of Appeals, the validity of OCT No. 239 of the spouses Layos
was already determined by the Supreme Court in its Decision in which the Supreme
Court categorically declared that the said certificate of title was a forgery.
The Spouses Layos, thus, filed before this Court the instant Petition for Review on
Certiorari. The Spouses Layos maintain that the Decision dated 16 December 1996 of
this Court in G.R. No. 120958 does not bar by res judicata their Petition for
Reconstitution there being no identity of parties, causes of action, and subject matters
between the two cases.
ISSUE: Whether or not the Court of Appeals erred in applying the principle of res
judicata in the instant case when it declared the ruling of SC in GR 120958 as
conclusive upon the issue of validity of the Reconstitution case.
HELD: The position of the Spouses Layos is untenable.
It is on the ground of res judicata, in its second concept —conclusiveness of judgment
— that the Petition for Reconstitution of the Spouses Layos must be dismissed.
Contrary to the position of the Spouses Layos, there is identity of parties and issues
between G.R. No. 120958 (the injunction cases) and LRC Case No. B-1784 (the
reconstitution case). The principal parties in both cases are the Spouses Layos, on one
hand, and La Paz and FEGDI, on the other. The Spouses Layos and La Paz both claim
title to the subject property, while FEGDI is the partner of La Paz in a joint venture to
develop the said property. There may be other parties named in both cases, but these
parties only derive their rights from the principal parties. The Court has previously
held that for purposes of res judicata, only substantial identity of parties is required
and not absolute identity. There is substantial identity of parties when there is
community of interest between a party in the first case and a party in the second case
even if the latter was not impleaded in the first case. In other words, privity or a shared
identity of interest is sufficient to invoke application of the principle of res judicata. It
is fundamental that the application of res judicata may not be evaded by simply
including additional parties in a subsequent litigation.
G.R. No. 173590. December 9, 2013
Petitioner: PHILIPPINE POSTAL CORPORATION
Respondent: COURT OF APPEALS and CRISANTO G. DE GUZMAN
FACTS:
De Guzman was charged for dishonesty and conduct grossly prejudicial to the best
interest as Postal Inspector at the Postal Services Office and eventually was relieved
from his post
Since the Postal Services Office was then a line-agency of the Department of
Transportation and Communication (DOTC), the charge against De Guzman was
forwarded to the Investigation Security and Law Enforcement Staff (ISLES). However,
the ISLES, through a Memorandum, Director Reyes recommended that De Guzman be
exonerated from the charges against him due to lack of merit. The said
recommendation was later approved by DOTC Asst. Secretary Jardiniano.
RA 7354 or the Postal Service Act of 1992, was passed. Pursuant thereto, the Postal
Services Office under the DOTC was abolished, and all its powers, duties, and rights
were transferred to the PPC. Likewise, officials and employees of the Postal Services
Office were absorbed by the PPC.
Subsequently, De Guzman, who had by then become Chief Postal Service Officer, was
formally charged and later on found guilty by PPC, for the same acts of dishonesty,
gross violation of regulations, and conduct grossly prejudicial to the best interest of
the service, and the Anti-graft law thereby dismissing him from service.
He filed a motion for reconsideration but was denied. A second MR was filed which
was resolved in his favor although he was found guilty of the charges, since the
complainant was the PPC, which had its own charter and was no longer under the
DOTC. Thus, the ISLES Memorandum which endorsed his exoneration and dismissal of
the complaints against him was merely recommendatory. As such, the filing of the
formal charge was an obvious rejection of said recommendation.
De Guzman’s motion for reconsideration was denied initially but the motion was, at
the same time, considered as an appeal to the PPC Board of Directors. Thus, in a
Resolution dated May 10, 2005, PG Rama pointed out that, being the third MR filed
by De Guzman, the same was in gross violation of the rules of procedure recognized
by the PPC, as well as of the Civil Service Commission (CSC), which both allowed only
one (1) such motion to be entertained. It was further held that res judicata was
unavailing as the decision exonerating De Guzman was ―only a ruling after a fact-
finding investigation. Hence, the same could not be considered as a dismissal on the
merits but rather, a dismissal made by an investigative body which was not clothed
with judicial or quasi-judicial power.
Meanwhile, before the issuance of the Resolution dated May 10, 2005, De Guzman
elevated his case on March 12, 2005 to the CA via a special civil action for certiorari
and mandamus.
On June 10, 2005, De Guzman appealed the Resolution dated May 10, 2005 before
the PPC Board. Almost a year later, the Board issued a Resolution denying the appeal
and affirming with finality his dismissal from service. The motion for reconsideration
subsequently filed was likewise denied.
On April 4, 2006, the CA reversed the PPC Resolutions. It held that the revival of the
case against De Guzman constituted grave abuse of discretion considering the clear
and unequivocal content of the Memorandum duly signed by Asec. Jardiniano that
the complaint against De Guzman was already dismissed.
Aggrieved, PPC moved for reconsideration which was, however, denied hence, the
instant petition.
Meanwhile, on July 26, 2006, De Guzman filed an appeal of the PPC Boards
Resolutions with the CSC which was, however, dismissed.
ISSUE: Whether the investigation conducted by the DOTC, through the ISLES, bars the
filing of the subsequent charges by PPC.
HELD:
The investigation conducted by the ISLES, which "provides, performs, and coordinates
security, intelligence, fact-finding, and investigatory functions for the Secretary, the
Department, and Department-wide official undertakings, "was intended precisely for
the purpose of determining whether or not a prima facie case against De Guzman
existed. Due to insufficiency of evidence, however, no formal charge was filed against
De Guzman and the complaint against him was dismissed by Asst. Secretary Jardiniano.
In order that res judicata may bar the institution of a subsequent action, the following
requisites must concur: (a) the former judgment must be final; (b) it must have been
rendered by a court having jurisdiction over the subject matter and the parties; (c) it
must be a judgment on the merits; and (d) there must be between the first and the
second actions (i) identity of parties, (ii) identity of subject matter, and (iii) identity of
cause of action.
A judgment may be considered as one rendered on the merits when it determines the
rights and liabilities of the parties based on the disclosed facts, irrespective of formal,
technical or dilatory objections; or when the judgment is rendered after a
determination of which party is right, as distinguished from a judgment rendered
upon some preliminary or formal or merely technical point.
In this case, there was no judgment on the merits, the dismissal of the complaint
against De Guzman in the Memorandum of Asec. Jardiniano was a result of a fact-
finding investigation only for purposes of determining whether a prima facie case
exists and a formal charge for administrative offenses should be filed. This being the
case, no rights and liabilities of the parties were determined therein with finality.
Hence, the Court holds that PPC did not gravely abuse its discretion when it revived
the case against De Guzman despite the previous dismissal thereof by Asec. Jardiniano.
Since said dismissal was not a judgment on the merits, the doctrine of res judicata
does not apply.
In fine, due to the errors of the CA as herein detailed, the Court hereby grants the
present petition and accordingly reverses and sets aside the farmer's dispositions. The
Resolutions dated November 23, 2004 and January 6, 2005 of the PPC ordering De
Guzman's dismissal from the service are thus reinstated.
The petition is granted.
G.R. No. 192486 November 21, 2012
Petitioner: Vda. de Viray
Respondent: Usi
FACTS:
At the core of the present controversy are several parcels of land which form part of
what was once Lot No. 733, Cad-305-D, Masantol Cadastre, registered in the name of
Ellen P. Mendoza (Mendoza), married to Moses Mendoza. On April 28, 1986, Geodetic
Engineer Abdon G. Fajardo prepared a subdivision plan (Fajardo Plan, for short) for
Lot 733, in which Lot 733 was divided into six (6) smaller parcels of differing size
dimensions. Mendoza executed two separate deeds of absolute sale, the first,
transferring Lot 733-F to Jesus Carlo Gerard Viray (Jesus Viray), and the second deed
conveying Lot 733-A to spouses Avelino Viray and Margarita Masangcay (Sps. Viray).
The aforementioned conveyances notwithstanding, Mendoza, Emerenciana M. Vda.
de Mallari (Vda. de Mallari) and respondent spouses Jose Usi and Amelita T. Usi (Sps.
Usi or the Usis), as purported co-owners of Lot 733, executed on August 20, 1990 a
Subdivision Agreement. Pursuant to this agreement, Lot 733 was subdivided into
three lots, i.e., Lots A to C, with the following area coverage: Lots 733-A, 465 square
meters, 733-B, 494 square meters, and 733-C, 6,838 square meters. The subdivision
of Lot 733, per the Galang Plan, and the two subdivision agreements concluded based
on that plan, virtually resulted in the loss of the identity of what under the Fajardo
Plan were Lot 733-A and Lot 733-F. The Sps. Viray and the late Jesus Viray, to recall,
purchased Lot 733-A and Lot 733-F, respectively, from Mendoza. As to be expected,
the foregoing overlapping transactions involving the same property or portions
thereof spawned several suits and counter- suits.
Of the six (6) cases, the first four (4) have been terminated and the main issue/s
therein peremptorily resolved. To a precise point, the matter of the validity of the
April 29, 1986 deeds of absolute sale conveying Lots 733-A and 733-F under the
Fajardo Plan to Sps. Viray and Vda. de Viray (vice Jesus Viray), respectively, is no longer
a contentious issue by force of the Court’s Decision in G.R. No. 122287 effectively
upholding the dismissal of the twin complaints to nullify the deeds aforementioned.
Likewise, the issue of who has the better possessory right independent of title over
the disputed lots has been resolved in favor of Vda. de Viray and the Sps. Viray and
against the Usis and veritably put to rest by virtue of the Court’s final, affirmatory
Decision in G.R. No. 154538.
ISSUE: Whether or not accion publiciana/reivindicatoria is barred by res judicata in
the instant case?
HELD:
Yes. Notably, the Sps. Viray and Vda. de Viray, after peremptorily prevailing in their
cases supportive of their claim of ownership and possession of Lots 733-A and 733-F
cannot now be deprived of their rights by the expediency of the Sps. Usi maintaining,
as here, an accion publiciana and/or accion reivindicatoria, two of the three kinds of
actions to recover possession of real property. The third, accion interdictal, comprises
two distinct causes of action, namely forcible entry and unlawful detainer, the issue
in both cases being limited to the right to physical possession or possession de facto,
independently of any claim of ownership that either party may set forth in his or her
pleadings, albeit the court has the competence to delve into and resolve the issue of
ownership but only to address the issue of priority of possession. Both actions must
be brought within one year from the date of actual entry on the land, in case of
forcible entry, and from the date of last demand to vacate following the expiration of
the right to possess, in case of unlawful detainer. When the dispossession or unlawful
deprivation has lasted more than one year, one may avail himself of accion publiciana
to determine the better right of possession, or possession de jure, of realty
independently of title. On the other hand, accion reivindicatoria is an action to recover
ownership which necessarily includes recovery of possession.
Res judicata operates as bar by prior judgment if the following requisites concur: (1)
the former judgment or order must be final; (2) the judgment or order must be on the
merits; (3) the decision must have been rendered by a court having jurisdiction over
the subject matter and the parties; and (4) there must be, between the first and
second action, identity of parties, of subject matter and of causes of action. All the
requisites are present in the instant case. The better right to possess and the right of
ownership of Vda. de Viray and the Sps. Viray over the disputed parcels of land cannot,
by force of the res judicata doctrine, be re-litigated thru actions to recover possession
and vindicate ownership filed by the Sps. Usi. The Court has in effect determined that
the conveyances and necessarily the transfers of ownership made to the Sps. Viray
and Vda. de Viray were valid. This determination operates as a bar to the Usis
reivindicatory action to assail the conveyances and precludes the re-litigation
between the same parties of the settled issue of ownership and possession arising
from ownership. It may be that the spouses Usi did not directly seek the recovery of
title or possession of the property in question in their action for annulment of the
deed sale of sale. But it cannot be gainsaid that said action is closely intertwined with
the issue of ownership, and affects the title, of the lot covered by the deed. The
prevalent doctrine is that an action for the annulment or rescission of a sale of real
property does not operate to efface the fundamental and prime objective and nature
of the case, which is to recover said real property.
G.R. No. 146980. September 2, 2003
Petitioner: LUZ E. TAGANAS and VALENTIN G. TABBAL
Respondent: HON. MELITON G. EMUSLAN AND STANDARD INSURANCE CO., INC.
FACTS:
On July 11, 1997, a road accident involving four vehicles occurred along the national
highway in Barangay San Jose, San Joaquin Sur, Agoo, La Union. The vehicles involved
were a "Jack and Yolly" minibus, an Izusu Elf van owned by Josalde and Zenaida Junto,
a Petron tanker truck owned and operated by petitioner Luz Taganas and a Shell
tanker truck. According to the records, the minibus, the Juntos' Isuzu Elf van and the
petitioner's Petron tanker truck were traveling in that order on one side of the road.
Going the opposite direction on the other side of the road was the Shell tanker truck.
The Isuzu Elf tried to overtake the minibus but collided head-on instead with the Shell
tanker truck, after which it swerved back to its lane, this time bumping the rear of the
minibus. The Petron tanker truck at the end of the column was not able to stop and
in turn rammed the rear of the Isuzu Elf van. The owners of the Elf van, the Juntos,
filed a complaint for damages against petitioners Luz Taganas and Valentin Tabbal,
the owner and driver respectively of the Petron tanker truck. The case was docketed
as Civil Case No. 97-02055-D.
On the other hand, private respondent, Standard Insurance Co., Inc., insurer of the
Shell tanker truck, filed a separate complaint for damages against both the Juntos and
petitioners Taganas and Tabbal, docketed as Civil Case No. 6754.
On March 10, 1999, petitioners filed a motion to dismiss Civil Case No. 6754 on the
grounds of prematurity of action and multiplicity of suits.
On April 5, 1999, Civil Case No. 97-02055-D was decided holding the owners of the
Izusu Elf van (the Juntos) liable for the damage sustained by petitioner Taganas'
Petron tanker truck.
On April 26 1999, the trial court, in Civil Case No. 6754, denied petitioners' motion to
dismiss.
On May 10, 1999 petitioners filed a "Second Motion to Dismiss," this time invoking
res judicata. In addition to said motion, petitioners likewise moved for the dismissal
of the Juntos' cross-claim against them.
On August 5, 1999, the trial court, in its first assailed order, granted the motion to
dismiss the cross-claim but denied the second motion to dismiss.
On August 30, 1999, petitioners filed a partial motion for reconsideration but the
same was denied in the second assailed order dated September 13, 1999.
Petitioners then elevated the case to the Court of Appeals via petition for certiorari
but it too was dismissed. Hence this instant petition.
ISSUE: Whether or not res judicata, as invoked by herein petitioners, is applicable in
this case.
HELD: No. For res judicata to apply, its essential elements must exist.
Clearly, there was, in the two cases, no identity of parties. The owner of the Shell
tanker truck was never a party in Civil Case No. 97-02055-D. Neither was the private
respondent insurance company a party therein. Since private respondent insurance
company, whose cause of action was legal subrogation to the rights of the owner of
the Shell tanker, was not a party in Civil Case No. 97-02055-D, it was not barred from
filing Civil Case No. 6754. Res judicata clearly did not apply to it.
On the issue of identity of subject matter, in Civil Case No. 97-02055-D, the subject
matter was the collision between the Isuzu Elf van owned by the Juntos and the Petron
tanker truck owned and operated by petitioner Luz Taganas. However, in Civil Case
No. 6754, the subject matter was the collision between the Shell tanker truck insured
by private respondent insurance company and the Isuzu Elf van of the Juntos which
was rear-ended by the Petron tanker truck of petitioner.
Finally, records reveal that Civil Case No. 97-02055-D was filed by the Juntos against
petitioners for the damage caused by petitioners' Petron tanker truck to the Juntos'
Isuzu Elf van. On the other hand, Civil Case No. 6754 was filed by private respondent
insurance company against both petitioners and the Juntos arising from the damage
suffered by the Shell tanker truck insured by it.
The Court therefore finds no reversible error committed by the Court of Appeals. The
decision of the trial court in Civil Case No. 97-02055-D was conclusive only as between
the petitioners and the Juntos, and not as to private respondent. Consequently,
the principle of res judicata did not apply.
G.R. No. 173148. April 6, 2015
Petitioner: ELSA DEGAYO
Respondent: CECILIA MAGBANUA-DINGLASAN
FACTS:
The present case involves a property dispute, which gave rise to two civil cases for
ownership and damages between conflicting claimants over a parcel of land located
on the northeastern bank of Jalaud River. The respondents initiated a second civil case
which eventually reached the Supreme Court. Records show that Lot No. 861 is a
36,864 sqm. parcel in the Cadastral Survey of Dingle, Iloilo, covered by Transfer
Certificate of Title (TCT) No. T-2804, registered in the name of Degayo’s deceased
parents, spouses Marcelo Olmo and Rosalia Labana. Lot No. 861 used to be bounded
on the southwest by the Jalaud River that serves to separate Dingle from Pototan Iloilo.
On the other side of Jalaud River, opposite Lot No. 861, lies a 153,028 square meter
parcel of land, designated as Lot No. 7328 of the Cadastre of Pototan, Iloilo,
collectively owned by the respondents, covered under TCT No. T-84829. The Jalaud
River, which separates these parcels of land, thus flows along the northeast side of
Lot 861 and the southwest side of Lot No. 7328. Sometime in the 1970’s the Jalauad
River steadily changed its course and moved southwards towards the banks of
Pototan, where Lot No. 7328 lies, leaving its old riverbed dry. Eventually, the course
of the Jalaud River encroached on Lot No. 7328. As a result, Lot No. 7328 progressively
decreased in size while the banks adjacent to Lot No. 861 gradually increased in land
area. Degayo and the tenants believed that the area was an accretion to Lot No. 861.
As a result, her tenants, commenced cultivating and tilling that disputed area with
corn and tobacco. The area allegedly added to Lot No. 861 contains 52,528 sqm.The
respondents, on the other hand, arguedthat the disputed property was an abandoned
riverbed, which should rightfully belong to them tocompensate for the erstwhile
portion of Lot No. 7328, over which the Jalaud River presently runs.
On October 2, 1984, the respondents filed a complaint for ownership and damages
against the tenants, with the Regional Trial Court (RTC) of Iloilo, Branch 27, entitled
Cecilia Magbanua Dinglasan, et al. v. Nicolas Jarencio, et al., docketed as Civil Case No.
16047. Degayo sought to intervene in Civil Case No. 16047 but her motion was denied.
Notably, Degayo never bothered to question the interlocutory order denying her
motion for intervention by filing a petition for certiorari. Instead, Degayo initiated the
present suit against the respondents for declaration of ownership with damages, also
with the RTC of Iloilo, Branch 22, docketed as Civil Case No. 18328, involving the
disputed parcel of land.
ISSUE: Whether or not Case No.16047 is a res judicata
HELD: The Decision in Civil Case No. 16047 constitutes res judicata.
In the present case, it is beyond dispute that the judgment in Civil Case No. 16047 has
attained finality in view of the tenant's abandonment of their appeal to the CA.
We likewise find that there is an identity of parties in Civil Case No. 16047 and the
present case. Absolute identity of parties is not required, shared identity of interest is
sufficient to invoke the coverage of this principle. Thus, it is enough that there is a
community of interest between a party in the first case and a party in the second case
even if the latter was not impleaded in the first case.
Likewise, there exists a community of interest between Degayo and her tenants, who
were respondents in Civil Case No. 16047. One test to determine substantial identity
of interest would be to see whether the success or failure of one party materially
affects the other. In the present case, Degayo is suing for the ownership of the
disputed land. Degayo's rights over the disputed land is predicated on the same
defenses that his alleged tenants interposed in Civil Case No. 16047, that is, their
perceived rights which emanated from the disputed accretion to Lot No. 861. The
interests of Degayo and the tenants in relation to the two cases are inextricably
intertwined in that both their claims emanate from a singular fundamental allegation
of accretion.
Moreover, Degayo and the respondents are litigating the same properties subject of
the antecedent cases inasmuch as they claim better right of ownership.
Notably, the ownership of the disputed parcel of land has been unequivocally settled
in Civil Case No. 16047. In ruling that the subject parcels of land belong to the
respondents, the RTC Branch 27 in Civil Case No. 16047 opined that the claim of
accretion has no valid basis. The fact that the present cause of action is based on an
accretion claim does not prevent the application of res judicata. For, res judicata,
under the concept of conclusiveness of judgment, operates even if no absolute
identity of causes of action exists. Res judicata, in its conclusiveness of judgment
concept, merely requires identity of issues. We thus agree with the uniform view of
the CA — on the application of conclusiveness of judgment to the present case.
G.R. No. 198356. April 20, 2015
Petitioner: ESPERANZA SUPAPO and the HEIRS OF ROMEO SUPAPO
Respondent: SPOUSES ROBERTO and SUSAN DE
JESUS
FACTS:
The Spouses Supapo filed a complaint which sought to compel the respondents to
vacate a piece of land located in Novaliches, Quezon City registered and titled under
the Spouses Supapo's names.
The Spouses Supapo did not reside on the subject lot but they made sure to visit at
least twice a year. During one of their visits in 1992, they saw two (2) houses built on
the subject lot. The houses were built without their knowledge and permission.
The Spouses Supapo demanded from the respondents the immediate surrender of
the subject lot by bringing the dispute before the appropriate Lupong Tagapamayapa.
Lupon issued Katibayan Upang Makadulog sa Hukuman (certificate to file action) for
failure of the parties to settle amicably.
The Spouses Supapo then filed a criminal case for violation of the Anti-Squatting Law.
The trial court convicted the respondents.
The respondents appealed their conviction to the CA. While the appeal was pending,
Congress enacted Republic Act (RA) No. 8368, otherwise known as "An Act Repealing
Presidential Decree No. 772," which resulted to the dismissal of the criminal case.
Spouses Supapo moved for the execution of the respondents' civil liability, praying
that the latter vacate the subject lot. RTC granted the motion and issued the writ of
execution. The respondents moved for the quashal of the writ but the RTC denied the
same. The RTC also denied the respondents' motion for reconsideration.
The respondents thus filed with the CA a petition for certiorari. The CA granted the
petition and held that with the repeal of the Anti-Squatting Law, the respondents'
criminal and civil liabilities were extinguished. The CA noted that recourse may be had
in court by filing the proper action for recovery of possession.
The Spouses Supapo thus filed the complaint for accion publiciana.
After filing their Answer, respondents moved to set their affirmative defenses for
preliminary hearing and argued that: (1) there is another action pending between the
same parties; (2) the complaint for accion publiciana is barred by statute of limitations;
and (3) the Spouses Supapo's cause of action is barred by prior judgment.
MeTC denied the motion to set the affirmative defenses for preliminary hearing.
MeTC likewise denied the respondents' motion for reconsideration. Respondents
then filed a petition for certiorari with the RTC. RTC granted the petition for certiorari
on two grounds: (1) the action has prescribed (2) accion publiciana falls within the
exclusive jurisdiction of the RTC.
In their motion for reconsideration, Spouses Supapo emphasized that the court's
jurisdiction over an action involving title to or possession of land is determined by its
assessed value; RTC does not have an exclusive jurisdiction on all complaints for accion
publiciana; and that the assessed value of the subject lot falls within MeTC's
jurisdiction. The RTC denied the petitioners' motion for reconsideration. It held that
although the MeTC had jurisdiction based on the assessed value of the subject lot, the
Spouses Supapos' cause of action had already prescribed, the action having been filed
beyond the ten (l0)-year prescriptive period under Article 555 of the Civil Code.
ISSUE: Whether the complaint for accion publiciana is barred by res judicata.
HELD: The petition is meritorious. We hold that the complaint is not barred by res
judicata.
Res judicata is not present in this case. It is obvious that the there is no identity of
subject matter, parties and causes of action between the criminal case prosecuted
under the Anti-Squatting Law and the civil action for the recovery of the subject
property.
The criminal complaint was prosecuted in the name of the people of the Philippines
while the accion publiciana was filed by and in the name of the Spouses Supapo. On
the other hand, the criminal case is a prosecution of a crime under the Anti-Squatting
Law while accion publiciana is an action to recover possession of the subject property.
There is no identity of parties between the criminal complaint under the Anti-
Squatting law and the civil action for accion publiciana. For this reason alone,
"conclusiveness of judgment" does not apply. Even if we assume, for the sake of
argument, that there is identity of parties, "conclusiveness of judgment" still does not
apply because there is no identity of issues. For all these reasons, the defense of res
judicata is baseless.

Spouses Supapo appealed to the CA. The CA dismissed the appeal. Spouses Supapo
moved but failed to secure a reconsideration of the CA decision; hence, they came to
us through the present petition.
G.R. No. 207286 July 29, 2015
Petitioner: DELA ROSA LINER, INC. AND/OR ROSAURO DELA ROSA, SR AND NORA
DELAROSA
Respondents: CALIXTO B. BORELA AND ESTELO A. AMARILE
FACTS:
On September 23, 2011, respondents Calixto Borela, bus driver, and Estelo Amarille,
conductor, filed separate complaints (later consolidated) against petitioners Dela
Rosa Liner, Inc., a public transport company for underpayment/non- payment of
salaries and other benefits, and violation of Wage Order Nos. 13, 14, 15 and 16.
In a motion dated October 26, 2011, the petitioners asked the labor arbiter to dismiss
the case for forum shopping. They alleged that on September 28, 2011, the CA 13th
Division disposed of a similar case between the parties after they entered into a
compromise agreement which covered all claims and causes of action they had
against each other in relation to the respondents' employment. The respondents
opposed the motion, contending that the causes of action in the present case are
different from the causes of action settled in the case the petitioners cited.
Labor Arbiter upheld the petitioners' position and dismissed the complaint on
grounds of forum shopping. Respondents appealed the LA's ruling.
On July 31, 2012, the National Labor Relations Commission (NLRC) 1st Division granted
the appeal, reversed the LA’s dismissal order, and reinstated the complaint. The NLRC
held that the respondents could not have committed forum shopping as there was no
identity of causes of action between the two cases.
The petitioners moved for reconsideration, but the NLRC denied their motion,
prompting them to file with the CA a petition for certiorari.
The CA 15th Division denied the petition. The NLRC likewise held that neither was the
case barred by res judicata arising from the CA judgment in the first case. The CA 15th
Division upheld the NLRC's (1st Division) decision and ruled out the presence of forum
shopping and res judicata as bars to the respondents' subsequent money claims
against the petitioners. The petitioners moved for reconsideration, but the CA denied
the motion in its resolution of May 21, 2013. Hence, this petition.
ISSUE: Whether or not the second complaint is barred by the rule on forum shopping
or by the principle of res judicata.
HELD: NO. Contrary to the petitioners' submission, respondents' second complaint, a
money claim, is not a "similar case" to the first complaint. Thus, the filing of the second
complaint did not constitute forum shopping and the judgment in the first case is not
a res judicata ruling that bars the second complaint
The first complaint charged the petitioners with illegal dismissal and unfair
labor practice; while the second complaint was based on the petitioners' alleged
nonpayment/underpayment of their salaries and monetary benefits, and violation of
several wage orders. We concur with the CA that forum shopping and res judicata are
not applicable in the present case. There is no identity of rights asserted and reliefs
prayed for, and the judgment rendered in the previous action will not amount to res
judicata in the action now under consideration. There is also no identity of causes of
action in the first complaint and in the second complaint because the same facts or
evidence would not support both actions.
USE OF FOREIGN JURISPRUDENCE
G.R. No. 148208. December 15, 2004
Petitioner: CENTRAL BANK (now Bangko Sentral ng Pilipinas) EMPLOYEES
ASSOCIATION, INC.
Respondent: BANGKO SENTRAL NG PILIPINAS
FACTS: The Central Bank (now BSP) Employees Association Inc, filed a Petition for
Prohibition against BSP and the Executive Secretary of the Office of the President, to
restrain respondents from further implementing the last provisio in Section 15 (c),
Article II of RA No 7653, on the ground that it is unconstitutional.
BACKGROUND:
July 3, 1993, RA No 7653 (The New Central Bank Act) took effect. It abolished the old
Central Bank of the Philippines and created a new BSP.
The issue that the Court tried to resolve in this case was: “Whether or not the last
paragraph of Section 15 (c), Article II of RA No 7653, runs afoul of the constitutional
mandate that “No person shall be … denied equal protection of the laws”
After a long deliberation to determine the constitutionality of the disputed provision,
the SC held that the last paragraph of Section 15 (c), Article II of RA No 7653, is
unconstitutional. During the course of the deliberation, the SC cited some foreign
jurisprudence which delved into the discussion of the equal protection under the
international lens. This included the equal protection of the United States and Europe.
ISSUE: WON foreign jurisprudence are binding on Philippine courts.
HELD: Admittedly, the view that prejudice to persons accorded special protection by
the Constitution requires a stricter judicial scrutiny finds no support in American or
English jurisprudence. Nevertheless, these foreign decisions and authorities are not
per se controlling in this jurisdiction. At best, they are persuasive and have been used
to support many of our decisions. We should not place undue and fawning reliance
upon them and regard them as indispensable mental crutches without which we
cannot come to our own decisions through the employment of our own endowments.
We live in a different ambience and must decide our own problems in the light of our
own interests and needs, and of our qualities and even idiosyncrasies as a people, and
always with our own concept of law and justice. Our laws must be construed in
accordance with the intention of our own lawmakers and such intent may be deduced
from the language of each law and the context of other local legislation related
thereto. More importantly, they must be construed to serve our own public interest
which is the be-all and the end-all of all our laws. And it need not be stressed that our
public interest is distinct and different from others.
In the 2003 case of Francisco v. House of Representatives, this Court has stated that:
"[A]merican jurisprudence and authorities, much less the American Constitution, are
of dubious application for these are no longer controlling within our jurisdiction and
have only limited persuasive merit insofar as Philippine constitutional law is
concerned. . . . [I]n resolving constitutional disputes, [this Court] should not be
beguiled by foreign jurisprudence some of which are hardly applicable because they
have been dictated by different constitutional settings and needs."
[Mao ni ang ruling sa SC in relation sa Issue sa case which I think is not needed na sa
digest nato – ako lang ni gibutang just in case gusto ka makahibaw sa actual ruling sa
SC sa case]
With the passage of the subsequent laws amending the charter of the other is premised precisely on the irrational discriminatory policy adopted by Congress in its
government financial institutions (GFIs), the continued operation of the last provisio treatment of persons similarly situated.
of Sec 15 (c), Art II of RA No 7653, constitutes invidious discrimination on the 2,994
rank-and-file employees of Banko Sentral ng Pilipinas. In the field of equal protection, the guarantee that “no person shall be denied the
equal protection of the laws” includes the prohibition against enacting laws that allow
The prior view on the constitutionality of RA 7653 was confined to an evaluation of its invidious discrimination, directly or indirectly.
classification between the rank-and-file and the officers of the BSP, found reasonable
because there were substantial distinction that made real differences between the 2 The equal protection clause does not demand absolute equality but it requires that all
classes. persons shall be treated alike, under like circumstances and conditions both as to
priveleges conferred and liabilities enforced. Favoritism and undue preference cannot
The subsequent enactments, however, constitute significant changes in circumstance be allowed. For the principles is that equal protection and security shall be given to
that considerably alter the reasonability of the continued operation of the last provisio every person under circumstance which, if not identical are analogous.
of Sec 15 (c), Art II of RA No 7653. This relates to the constitutionality of classifications
between the rank-and-file of the BSP and the 7 other GFIs. The classification must not
only be reasonable, but must also apply equally to all members of the class. The
provisio may be fair on its face and impartial in appearance but it cannot be grossly
discriminatory in its operation, so as practically to make unjust distinctions between
persons who are without differences.

The inequality of treatment cannot be justified on the mere assertion that each
exemption rests on the policy determination by the legislature. The policy
determination argument may support the inequality of treatment between the rank-
and-file and the officers of the BSP, but it cannot justify the inequality of treatment
between the rank-and-file of the BSP and the 7 other GFIs who are similarly situated.

The issue is not the declared policy of the law per se, but the oppressive results of
Congress inconsistent and unequal policy towards the rank-and-file of the BSP and the
7 other GFIs. The challenge to the constitutionality of Sec 15 (c), Art II of RA No 7653