Tala Realty Services Inc et al vs Banco Filipino Savings & Mortgage Bank

G.R. No. 181369, June 22, 2016

Facts:

In September 1995, Banco Filipino filed a complaint against Tala Realty Services Corporation,
Inc. (Tala Realty) and the individual petitioners. The complaint alleged that the properties were
under a trust agreement between Banco Filipino, as trustor-beneficiary, and Tala Reality, as
trustee for the purpose of allowing more flexibility in the opening of branches and as such,
enable to bank to have new branch sites.
Petitioners moved to dismiss the complaint however, the RTC initially denied. It ordered the
dismissal of the complaint against petitioners except Tala Realty and ordered the suspension of
the proceedings in view of the decision in G.R. No. 137533.
The case was subsequently elevated to the CA wherein the proceedings from the case should not
have been suspended since the matter resolved in the aforementioned case is originated from an
ejectment suit and is distinct and separate from the subject matter.
Hence, the CA denied the petitioners’ motion for reconsideration.

Issue:

WON the principle of stare decisis was validly applied to deny Banco Filipino’s claims for
reconveyance

Ruling:

Yes. The principle of stare decisis was validly applied to the instant case and with this, Banco
Filipino’s action for reconveyance of the property cannot prosper and must be dismisse due to
lack of cause of action. As explained by the Court, the doctrine is a bar to any attempt to
relitigate the sameissue where the same questions relating to the same event has been resolved
and is similrlysituted in a preceeing case and by which decided by a competent court. This
doctrine is to ensure the necessity for securing certainty and stability of judicial decisions.
 United Coconut Planters Bank vs Spouses Walter Uy and Lily Uy
G.R. No. 204039, January 10, 2018

Facts:

In 1997, the respondents, Walter and Lily Uy entered into a contrat to sell with Prime Town
Property Group, Inc. (PPGI) for a unit at Kiener Hills for a price amounted to P1,151,718.75
payable according to their agreed terms and conditions.
In October 1998, PPGI and petitioner United Coconut Planters Bank (UCPB) executed a
Memorandum of Agreement which PPGI transferred the right to collect the receivables of the
buyers, including respondents, of the units.
In April 2006, the respondents filed for a complaint for sum of money and damages against PPGI
and UCPB due to PPGI’s failure to complete the construction of their units.
In the CA’s assailed decision, affirming and modifying the OP decision, it applied the case of
United Coconut Planters Bank v. O’Halloran for having similar facts and issues. As such, the
appellate court partially granted the petition for review.

Issue:

WON the CA erred in applying the principle of stare decisis

Ruling:

The petition is meritorious. In the instant case, the Supreme Court ruled that the CA erred when
it misconstrued the applicability of the principle of stare decisis in the case of UCPB v.
O’Hallran (CA-G.R. SP No. 101699). As explained by the Court in De Mesa v. Pepsi-Cola
Product Phils. Inc., stare decisis applies only to cases decided by the Supreme Court. Courts are
required to follow a rule already established in a final decision of the Supreme Court. That
decision becomes a judicical precedent to be followed in subsequent cases by all courts. Thus,
the doctrine of stare decisis becomes oprative only when judicial precedents are set by the
pronouncement of the Supreme Court, excluding the lower courts as the latter’s decisions only
has a persuasive effect. With this, the respondents were correct in contesting the CA on their
application of the doctrine. The decision of the CA is wherefore, affirmed with modification.
 De Mesa v Pepsi Cola Products Phils. Inc.
GR Nos. 153063-70, Aug. 19, 2005

Facts:

Respondents, Pepsi Cola Products Inc. (PCPPI) and PEPSICO, Inc. (PI) held a contest wherein
the D.G. Consultores was tasked to randomly pre-select the winning numbers and send to
respondents a list of 60 winning numbers including their assigned security codes.
On February 17 to May 28 1992, during the initial promotional period, respondents seeded 1000
numbers and 60 of which were winning numbers. As a result of the promotional success, the
respndents extended the campaign from May 10 to June 12, 1992. And once again, D.G.
Consultores were to select an additional 25 winning numbers.
On May 25, 1992, respondents announced that “349” was the winning number. On the similar
day, Quintin Gomez Jr., manager of PCPPI, calleted the Department of Trade and Industry (DTI)
to inform her that there was a mistake on the announcement. Thus, holders of the supposed
winning number “349” were not honored which then resulted to numerous complaints.
Petitioners filed their separate complaints with the RTC a motion to dismiss invoking the
principle of stare decisis.

Issue:

WON the RTC validly dismissed the petitioners’ complaint on the ground of res judicata

Ruling:

The Supreme Court finds the instant motion meritorious under the principle of stare decisis. In
the instant case, the legal rights and relations of the parties, including the applicable laws, causes
of action, issues, and the evidence are similar to Mendoza and Rodrigo cases which have been
previously decided by th Court. With this, the issue has been settled and this Court’s final
decision in the preceeding cases must be respected as entrenched in Article 8 of the Civil Code
which provides, “Judicial decisions applying or applying the laws or the Constitution shall form
a part of the legal system in the Philippines.” Wherefore, the instant petition is denied and
consequently, the RTC was correct in dismissing the petitioners’ complaint.
 Commissioner of Internal Revenue v. The Insular Life Assurance Co. Ltd.
G.R. No. 197192, June 4, 2014

Facts:

Commissioner of Internal Revenue (CIR), petitioner, as mandated by the National Internal

Revenue Code (NIRC) of 1997 is the official duly authorized to assess and collect internal
revenue taxes, and decide disputed assessments.
The Insular Life Assurance, Co., Ltd., respondent, is a corporation duly organized and existing
under the Philippine law.
In October 2004, respondent received an assessmnt notice due to deficiency Documentary Stamp
Taxes (DST) on its premiums on direct business for year 2002. Insular Life consequently filed a
protest letter, which was denied by the CIR due to lack of factual and legal basis.
The respondent then filed a petition before the CTA and it finds that the respondent is exempt
from the DST on the insurance policies it grants to its members.
Petitioner filed a petition for reiew and was likewise denied for lack of merit.

Issue:

WON the CTA was correct in the application of the doctrine of stare decisis

Ruling:

Yes. The Sunlife case and the present case according to the factual circumstances are
substantially similar with each other. The CTA based its assailed decision on the doctrine decided
by the Court. Thus, where the same questions relating to the same event have been put forwrd by
the parties similarly situation in a preceding case, the rule of stare decisis applies in order to bar
any attempt that would relitigate the same issue. Wherefore, the petition is denied.
5) What is res judicata?

Res judicata is when any of the complaints are terminated by final judgement or it means a case
has already been decided and is final and executory. The principle res judicata is for the purpose
of not permitting the parties to litigate the same issues more than once, when a right or facts been
judicially tried and determined a court of competent jursidiction.

6) Is res judicata the same as stare decisis doctrine? Explain your answer.

No, they are not the same. Res judicata essentially means that a case has been already decided or
a cse is settled by a decision or judgment by the court. Thus, it is based on the conclusivenss of
the judgement. While stare decisis is where there is a similarity of facts, issues, and laws
applicable to previous cases which is involved in the present case. If such are similar, this
doctrine is applied to stand by the decisions and disturb not what is settled.