5. Veloso, Jr. v.

Court of Appeals, 261 SCRA 196 (1996)

Petitioners:

Nicolas Veloso, Jr.

Concepcion Veloso Patalinghug
Eduardo Veloso
Ligaya Veloso Roa
Rafael Veloso
Emerenciana Veloso Cabigon
Domingo Veloso
Emmanuel Veloso

Respondents:

Court of Appeals
Regional Trial Court Brach 14 (Baybay, Leyte)
Corsini Miraflor Avellana
Aureo Peñalosa Miraflor
Eddie Peñalosa Miraflor
Douglas Peñalosa Miraflor

FACTS:
On September 12, 1988, the respondents Corsini Miraflor Avellana, Aureo Peñalosa Miraflor,
Eddie Peñalosa Miraflor, and Douglas Peñalosa Miraflor filed a complaint before the Regional
Trial Court (RTC) of Baybay, Leyte, docketed as Civil Case No. B-1043. The complaint was
filed for the purpose of quieting title with damages against the petitioners.
The subject matter of the complaint was Lot No. 8422-F, which was covered by Transfer
Certificate of Title (TCT) No. 22393. TCT No. 22393 was originally in the name of Crispina
Peñalosa Miraflor, who was the deceased mother of the respondents.
On August 31, 1990, the RTC rendered a judgment in favor of the respondents in Civil Case No.
B-1043. The RTC's judgment included the following key points:
It found TCT No. T-22393 authentic, valid, indefeasible, and entitled to all faith and credence
under Act 496. It declared the respondents as absolute co-owners in fee simple of Lot No. 8422-
F. It directed the petitioners, or anyone in possession of Lot No. 8422-F, to deliver physical and
material possession of the property to the respondents, along with all improvements on it. It
ordered the petitioners in solidum to pay the respondents P5,000.00 as attorney’s fees and
P2,000.00 as reimbursement for litigation expenses.
The petitioners then appealed the RTC's decision to the Court of Appeals. On May 28, 1992, the
Court of Appeals affirmed the RTC's decision, upholding the judgment in favor of the
respondents.
The petitioners, dissatisfied with the Court of Appeals' decision, sought review from the Supreme
Court. However, on October 12, 1992, the Supreme Court denied their petition, stating that the
issues raised were essentially factual, and there was no showing that the findings of fact of the
Court of Appeals were not supported by substantial evidence.
An order for the entry of judgment was issued on March 15, 1993. Despite these setbacks, on
September 20, 1993, the petitioners sought the annulment of the RTC's decision in Civil Case
No. B-1043 before the Court of Appeals.
On July 29, 1994, the Court of Appeals ruled against the petitioners. The Court of Appeals found
that the controversy had already been settled by the Supreme Court and that the contention that
the RTC did not have the power or authority to amend, alter, or modify the decisions of a co-
equal court should have been raised in the previous proceedings.
ISSUE:
Whether or not the Court of Appeals erred in refusing to declare the RTC's decision void.
RULING:
Yes, the Court of Appeals did not err in refusing to declare the RTC's decision void.
The law of the case doctrine is based on the principle that a decision made by a higher court on
an issue of law in a particular case is binding and controlling upon the same court in subsequent
stages of the same case. In simpler terms, when a court makes a final decision on a legal case,
that decision is considered the final say on who rightfully owns a property or who is involved in
the legal action. It means that the court's judgment is the ultimate decision that everyone must
follow regarding property ownership, or the people involved in the case.
In the case at bar, the previous judgments and decisions in Civil Cases Nos. R-205 and B-122
had already conclusively settled certain matters related to the property in question, including
ownership and possession. Therefore, these matters could not be relitigated in Civil Case No. B-
1043. The Court pointed out that it had previously affirmed the judgment in Civil Case No. B-
1043. Therefore, the issues and matters determined in that case were binding and could not be
revisited in subsequent proceedings.
Thus, the Supreme Court upheld the decision of the Court of Appeals, denied the petition for
review, and affirmed the lower courts' rulings.
6. Agustin v. Court of Appeals, 271 SCRA 457
Petitioners:
Leovillo C. Agustin
Respondents:
Court of Appeals
Filinvest Finance Corporation
FACTS:
On October 28, 1970, petitioner Leovillo C. Agustin executed a promissory note in favor of
ERM Commercial for the amount of P43,480.80. The promissory note was payable in monthly
installments and was secured by a chattel mortgage over an Isuzu diesel truck. Both the
promissory note and the chattel mortgage were subsequently assigned to private respondent
Filinvest Finance Corporation.
Agustin defaulted on the installment payments, prompting Filinvest Finance Corporation to
demand full payment or the surrender of the mortgaged vehicle. Agustin failed to make the
payment or surrender the vehicle, leading Filinvest Finance Corporation to file a complaint in the
Regional Trial Court (RTC) of Manila, Branch 26. The complaint sought the issuance of a writ of
replevin or, alternatively, the payment of P32,723.97 plus interest.
RTC Branch 26 granted the writ of replevin, allowing Filinvest Finance Corporation to repossess
the vehicle. However, upon repossession, Filinvest Finance Corporation discovered that the
vehicle was no longer in running condition and that several parts were missing. The vehicle was
subsequently foreclosed and sold at public auction.
Filinvest Finance Corporation filed a "supplemental complaint" claiming additional
reimbursement, including the value of replacement parts and expenses incurred in transporting
the mortgaged vehicle from Cagayan to Manila.
Agustin moved to dismiss the supplemental complaint, arguing that RTC Branch 26 had lost
jurisdiction due to the earlier foreclosure of the chattel mortgage. The lower court granted
Agustin's motion, resulting in the dismissal of the case.
Filinvest Finance Corporation appealed the dismissal to the Court of Appeals (CA), docketed as
CA-G.R. No. 56718-R. The CA set aside the order of dismissal and ruled that repossession
expenses incurred by Filinvest Finance Corporation should be reimbursed.
The decision in CA-G.R. No. 56718-R became final and executory, leading to the case being
remanded to the Regional Trial Court of Manila, Branch 40 (RTC Branch 40) to determine the
correct amount due from Agustin. After a trial, RTC Branch 40 found Agustin liable for
repossession expenses, attorney's fees, liquidated damages, bonding fees, and other expenses,
totaling P18,547.38.
Agustin moved for reconsideration, and RTC Branch 40 modified its decision by reducing the
monetary award to P8,852.76, the amount originally prayed for in the supplemental complaint.
Both parties appealed the decision of RTC Branch 40. Filinvest Finance Corporation appealed
regarding the reduction of the amount awarded, while Agustin appealed the order requiring him
to pay P8,852.76.
The appeals were consolidated in CA-G.R. No. 24684, where the modified order of RTC Branch
40 was affirmed by the CA. Agustin filed a motion for reconsideration with the CA, which was
denied. Hence, Agustin filed a petition for review on certiorari with the Supreme Court.
ISSUE:
Whether or not CA’s previous decision regarding the award of repossession expenses should be
considered as the final and controlling rule for subsequent appeals.
RULING:
Yes, the Court of Appeals' previous decision regarding the award of repossession expenses
should be considered as the final and controlling rule for subsequent appeals.
The "law of the case" doctrine means that when an appellate court has already ruled on a
particular question or issue in a previous appeal and remanded the case to the lower court for
further proceedings, that ruling becomes the established and controlling rule for subsequent
appeals. The parties are not allowed to reopen or relitigate previously settled issues in later stages
of the case.
In the case at bar, Agustin's contentions had been previously rejected by the Court of Appeals in
CA-G.R. No. 56718-R, and that decision had become final.
Therefore, the appellate court had already settled the propriety of awarding repossession
expenses in favor of Filinvest Finance Corporation.

The remand of the case to RTC Branch 40 was solely to determine the correct amount of
expenses and not to relitigate the accuracy of the award.
Even if the "law of the case" doctrine were disregarded, the award for repossession expenses was
still proper. An exception to the rule under Article 1484 (3) of the Civil Code applied in cases
where the mortgagor refuses to deliver the mortgaged property or conceals it to place it beyond
the reach of the mortgagee. In such cases, the necessary expenses incurred in prosecuting the
action for replevin, including seizure of the property and reasonable attorney's fees, should be
borne by the mortgagor. The denial of the award for attorney's fees was justified, as there was no
evidence presented to support the claim.
Thus, the Supreme Court affirmed the award of repossession expenses to Filinvest Finance
Corporation and the denial of attorney's fees.
7. Degayo v. Magbanua-Dinglasan, G.R. Nos. 173148 (April 6, 2015)
Petitioners:
Elsa Degayo
Respondents:
Cecilia Magbanua-Dinglasan
Johnny Dinglasan
Asuncion Magbanua-Porras
Mariano Pascualito Magbanua
Amado Jr. Magbanua
FACTS:
The case revolves around a property dispute over Lot No. 861, a 36,864 sqm. parcel of land
located near the Jalaud River in Dingle, Iloilo. Lot No. 861 was originally registered in the name
of Elsa Degayo's deceased parents, spouses Marcelo Olmo and Rosalia Labana. On the opposite
side of Jalaud River lies Lot No. 7328, a 153,028 square meter parcel of land, collectively owned
by the respondents and covered by TCT No. T-84829. The river separated Lot No. 861 from Lot
No. 7328.
In the 1970s, the Jalaud River gradually changed its course, encroaching on Lot No. 7328 and
leaving its old riverbed dry. The change in the river's course resulted in an increase in the land
area adjacent to Lot No. 861, which Elsa Degayo believed to be an accretion to her property.
Degayo's tenants began cultivating and tilling the disputed area, totaling 52,528 sqm., which
included the original abandoned riverbed and the resurfaced area of Lot No. 7328. The
respondents argued that the disputed property was an abandoned riverbed that rightfully
belonged to them, as compensation for the portion of Lot No. 7328 lost due to the river's course
change.
Two civil cases were initiated: Civil Case No. 16047 by the respondents against the tenants of
Lot No. 861 and Civil Case No. 18328 by Elsa Degayo against the respondents, both involving
the disputed parcel of land. In Civil Case No. 16047, the Regional Trial Court (RTC) ruled in
favor of the respondents, stating that the disputed land was an abandoned riverbed belonging to
them. Degayo sought to intervene in Civil Case No. 16047 but was denied. Elsa Degayo then
initiated Civil Case No. 18328, asserting her ownership claim over the disputed land. The RTC
ruled in her favor, declaring the land an accretion to Lot No. 861.
The respondents appealed to the Court of Appeals (CA), which reversed the RTC's decision in
Civil Case No. 18328. The CA held that the disputed properties were abandoned riverbeds and
ruled in favor of the respondents.
ISSUE:
Whether or not the prior decision in Civil Case No. 16047 legally prevents the re-litigation of the
same issues and claims in Civil Case No. 18328.
RULING:
Yes, the prior decision in Civil Case No. 16047 legally prevents the re-litigation of the same
issues and claims in Civil Case No. 18328.
The doctrine of res judicata, specifically the bar by prior judgment, is defined as a legal principle
that prevents the relitigation of the same issues, claims, and facts in a subsequent case when a
prior judgment by a competent court has already conclusively settled those matters.
In the case at bar, the prior decision in Civil Case No. 16047, which favored the respondents, has
a binding effect and precludes Elsa Degayo from reasserting identical claims and issues in the
subsequent case, Civil Case No. 18328.
Thus, the prior decision in Civil Case No. 16047 prevents the re-litigation of the same issues in
Civil Case No. 18328.

8. Villa v. Sandiganbayan, 208 SCRA 283 (1992)

Petitioners:
Camilo Villa
Respondents:
Sandiganbayan
People of the Philippines
FACTS:
Camilo Villa, the petitioner, was among those accused in a case filed before the Sandiganbayan.
The case involved allegations of violating the Anti-Graft and Corrupt Practices Act (R.A. 3019)
in relation to a procurement transaction. The specific charge against Villa was his participation as
a member of the Bidding Committee and his signing of the Abstract of Bids and approval of the
lowest bid in favor of Rocen Enterprises.
The controversy stemmed from a procurement transaction where electrical items were purchased
from Rocen Enterprises. Rocen Enterprises, at the time of the transaction, dealt exclusively in
paper products and printed matter and was not considered a reputable supplier of electrical items.
The Sandiganbayan found Villa guilty of violating paragraphs (a) and (e) of Section 3, R.A.
3019, in relation to an Unnumbered Presidential Memorandum dated April 22, 1971. These
violations pertained to Villa's role in awarding the purchase contract to Rocen Enterprises, a
supplier not known for electrical items.
ISSUES:
Whether or not the previous decision of the Sandiganbayan, which found Villa guilty of
violations under R.A. 3019 precludes the re-litigation of the same charges and issues.
RULING:
Yes, the previous decision of the Sandiganbayan, which found Villa guilty of violations under
R.A. 3019, precludes the re-litigation of the same charges and issues.
Res judicata prevents the same parties from re-litigating the same issues that have already been
conclusively decided by a competent court. Once a judgment has been rendered in a case and has
become final, the same parties cannot bring the same issues before the court again, even if new
evidence or arguments are presented.
In the case at bar, the Sandiganbayan had already rendered a decision finding Villa guilty of
violations under R.A. 3019 for his involvement in awarding the purchase contract to Rocen
Enterprises, a supplier not reputable for electrical items. The Sandiganbayan's decision was
based on the evidence presented and the application of the relevant laws.
Thus, the Supreme Court ruled that the previous Sandiganbayan decision constituted a bar to the
re-litigation of the same charges and issues against Camilo Villa. The appeal was denied, and
Villa's conviction was affirmed.

9. Padillo v. Court of Appeals, 371 SCRA 27 (2001)

Petitioners:

Veronica Padillo

Respondents:
Court of Appeals
Tomas Averia, Jr.

Beato Casilang
FACTS:
The case revolves around a disputed parcel of land in Lucena City covered by TCT No. T-9863
and the building erected on it. Tomas Averia, Jr. initiated M.C. No. 374-82, a registration case,
seeking to register certain documents of title related to the property. During the pendency of
M.C. No. 374-82, Veronica Padillo filed two separate civil cases:
 1. Civil Case No. 1690-G: Padillo's first case, filed against Averia, was dismissed on
grounds of improper venue.
2. Civil Case No. 9114: Padillo's second case, filed against Averia, aimed to recover
damages arising from the property dispute.
In M.C. No. 374-82, the Supreme Court ordered a new trial with expanded jurisdiction for the
Regional Trial Court (RTC) in Lucena City. The RTC ultimately ruled in favor of Averia,
declaring him the owner of the disputed property. The Court of Appeals affirmed the RTC's
decision in M.C. No. 374-82.
Padillo's petition to challenge the Court of Appeals' decision in M.C. No. 374-82 was denied by
the Supreme Court. In Civil Case No. 9114, the RTC ordered Averia to vacate the property and
pay Padillo various amounts, including unrealized income, attorney's fees, moral damages,
exemplary damages, and litigation expenses.
ISSUES:
Whether or not the earlier judgment in M.C. No. 374-82 should bar the subsequent case in Civil
Case No. 9114.
RULING:
Yes, the earlier judgment in M.C. No. 374-82 should bar the subsequent case in Civil Case No.
9114.
Res judicata means that once a court has rendered a final judgment on a matter, such as the
ownership and possession of the disputed property, that judgment is conclusive and cannot be re-
litigated in a subsequent case between the same parties.
In the case at bar, both M.C. No. 374-82 and Civil Case No. 9114 involve the same parties
(Padillo and Averia), the same subject matter (the disputed property covered by TCT No. T-
9863), and the same cause of action (ownership and possession of the property). The judgment in
M.C. No. 374-82, which declared Averia as the owner, has already settled these issues.
Thus, the judgment in M.C. No. 374-82, which declared Averia as the owner of the property,
serves as a bar to the claims made by Padillo in Civil Case No. 9114, as they involve the same
issues and parties.
10. Antonio v. Vda. De Monje, 631 SCRA 471 (2010)
Petitioners:
Conrado Antonio
Avelyn Antonio
Respondents:
Julita Sayman Vda. De Monje
Angelina Monje-Villamor
Luzvisminda Monje-Cortel
Marrieta Monje-Ortico
Leopoldo Monje
Concepcion Sayman-Monje
Rolinda Monje-Calo
FACTS:
Spouses Catalino Manguiob and Andrea Pansaon were the original owners of a parcel of coconut
land known as Lot No. 1 in Davao, covering 15,903 square meters. In 1962, Andrea Pansaon,
along with other heirs, sold 7,500 square meters of Lot No. 1 to Macedonio Monje. This sale was
duly notarized.
In 1967, the heirs of Catalino Manguiob and Andrea Pansaon, who had also passed away, sold
the entire Lot No. 1 to Nicanor Manguiob and Carolina V. Manguiob. Subsequently, Nicanor
Manguiob and Carolina V. Manguiob sold the entire Lot No. 1 to Avelyn B. Antonio. Macedonio
Monje, the original purchaser of the 7,500 square meter portion, learned of this sale in August
1967.
Macedonio Monje filed a complaint in 1967 before the CFI (now RTC) of Baganga, Davao
Oriental, seeking the annulment of the sale to Nicanor Manguiob and Carolina V. Manguiob, as
well as the subsequent sale to Avelyn Antonio and the cancellation of TCT No. T-9643. The case
was docketed as Civil Case No. 007-125.
In August 1981, the CFI rendered a decision declaring the second and third deeds of sale and
TCT No. T-9643 null and void. It also ordered the defendants to pay Macedonio Monje moral
and actual damages.
The defendants, identified as Spouses Conrado Antonio and Avelyn Antonio (petitioners),
appealed the CFI decision to the Supreme Court. In December 1992, the Supreme Court affirmed
the decision with a clarification regarding the property's size.
Subsequently, Spouses Conrado Antonio and Avelyn Antonio filed a new case, Civil Case No.
506, before the RTC of Baganga, Davao Oriental, Branch 7. In this case, they sought a sum of
money, accounting of copra proceeds, damages, and attorney's fees against the respondents,
successors of Macedonio Monje.
Respondents filed a motion to dismiss Civil Case No. 506, citing res judicata and other grounds.
On December 16, 1994, the RTC dismissed Civil Case No. 506 on the ground of res judicata.
Spouses Conrado Antonio and Avelyn Antonio (petitioners) appealed the RTC's decision to the
Court of Appeals (CA), arguing that there was no res judicata between the two cases. The CA
affirmed the RTC's decision, leading to the filing of a petition before the Supreme Court by
Spouses Conrado Antonio and Avelyn Antonio.
ISSUES:
Whether or not the principle of res judicata should bar the subsequent case (Civil Case No. 506)
in relation to the earlier judgment in Civil Case No. 007-125.
RULING:
No, the principle of res judicata should not bar the subsequent case (Civil Case No. 506) in
relation to the earlier judgment in Civil Case No. 007-125.
The principle of conclusiveness of judgment means that any right, fact, or matter in issue that
was directly adjudicated or necessarily involved in the determination of an action before a
competent court in which judgment is rendered on the merits is conclusively settled by that
judgment. It cannot be litigated again in any future or other action between the same parties or
their privies and successors-in-interest, in the same or any other court of concurrent jurisdiction,
either for the same or a different cause of action.
In the case at bar, Civil Case No. 007-125 focused on the 7,500 square meter portion of Lot No.
1, while Civil Case No. 506 concerned the remaining 8,403 square meters. Since there was no
identity of subject matter or causes of action, res judicata did not apply. The Court reversed the
decisions of the Court of Appeals and directed the remand of the case to the Regional Trial Court
for appropriate proceedings on the merits.
Thus, the ruling of the Supreme Court was in favor of the petitioners, finding that res judicata did
not bar their claims in Civil Case No. 506.
11. Republic v. Yu, 484 SCRA 416 (2006)
Petitioners:
Republic of the Philippines (Civil Aeronautics Administration)
Respondents:
Ramon Yu
Teofista Villamala
Lourdes Yu
Yu Se Peng
FACTS:
This case revolves around the ownership and reversion of Lot No. 939 in Lahug, Cebu City,
which was initially subject to expropriation proceedings. In Valdehueza v. Republic (1966), the
Supreme Court affirmed the judgment of expropriation, specifying that the petitioners were
entitled only to the fair market value of the lot, not its possession. Subsequently, in Yu v.
Republic (1986), the Court of Appeals invalidated the sale of Lot No. 939 to the respondents,
alleging that they were not purchasers in good faith. This decision became final and executory as
no appeals were made.
In response, the respondents filed a complaint for reversion of the expropriated property on
October 1, 1992. The Republic of the Philippines, as the petitioner, countered this by denying the
respondents' right to reacquire the property. They argued that res judicata, lack of cause of action,
and forum-shopping should bar the respondents' claim. The trial court, on November 16, 1995,
dismissed the complaint on the grounds of res judicata.
The Court of Appeals later disagreed with the trial court's application of res judicata, and as a
result, they remanded the case for further proceedings. This led to the petitioner's appeal to the
Supreme Court.
ISSUES:
Whether or not the trial court erred in dismissing the respondents' complaint based on the
doctrine of res judicata, specifically the doctrine of conclusiveness of judgment.
RULING:
No, the trial court did not err in dismissing the respondents' complaint based on the doctrine of
res judicata, specifically the doctrine of conclusiveness of judgment.
Res judicata, particularly the doctrine of conclusiveness of judgment, means that when a final
judgment on the merits has been rendered by a court of competent jurisdiction, it is conclusive as
to the rights of the parties and prevents the relitigation of issues or matters that were already
resolved in the previous case.
In the case at bar, the Supreme Court ruled in favor of the petitioner, thus affirming the Regional
Trial Court's decision to dismiss the respondents' complaint and setting aside the Court of
Appeals' ruling. The Court based its decision on the application of the doctrine of res judicata,
specifically the doctrine of conclusiveness of judgment. It reasoned that the respondents sought
to enforce a right based on a sale that had been nullified by a final and executory judgment in Yu
v. Republic (1986).
Consequently, the Court concluded that the respondents lacked legal standing (i.e., no legal
personality to sue) to bring an action for the reversion of the expropriated property. Emphasizing
that the sale, which formed the basis of the respondents' claim, had long been invalidated, the
Court held that they had no legal right over the property.
Thus, the trial court's dismissal based on res judicata, specifically conclusiveness of judgment,
was upheld. The respondents couldn't relitigate their claim, as it was settled in a prior case.

12. Firestone Ceramics, Inc. v. Court of Appeals, 313 SCRA 522 (1999)
Petitioners:
Firestone Ceramics, Inc.
Boomtown Development Corporation
Cynthia D. Ching
Ching Tiong Keng
Carmen Soco
Lorenzo Ong Eng Chong
Soledad B. Yu
Yu Sy Chia
Leticia Nocom Chan
Respondents:
Court of Appeals
Lorenzo J. Gana
Patrocinio E. Margolles
Alice E. Sotto
Virginia E. Villongco
Edgardo C. Espinosa
Teresita E. Casal
Peltan Development, Inc.
Regional Trial Court
Register of Deeds of Las Pinas, Metro Manila
Petitioner-Intervenor:
Alejandro B. Rey
FACTS:
This case involves the same land dispute as the one discussed in G.R. No. 127245. It centers on
the validity of Original Certificate of Title (OCT) No. 4216 issued to the Gana spouses in 1929.
Several private individuals and corporations, including Firestone Ceramics, Inc., Boomtown
Development Corporation, and others, sought the cancellation of OCT No. 4216, asserting that
the land in question was unclassified public land (forest land) when the title was granted. They
contended that the Court of First Instance (CFI) of Rizal, acting as the Land Registration Court,
lacked jurisdiction to award it to the Gana spouses.
The RTC, which was previously the CFI of Rizal, issued a decision dismissing the petition to
cancel OCT No. 4216. The RTC cited the doctrine of res judicata, particularly the Margolles
case, where the Supreme Court had already upheld the validity of OCT No. 4216. The RTC ruled
that the matter was already conclusively decided, and there was no substantial difference in the
parties' arguments from those presented in the Margolles case.
The petitioners appealed to the CA, but the CA affirmed the RTC's decision. It found that the
Margolles case conclusively settled the issue regarding the validity of OCT No. 4216 and that the
doctrine of res judicata applied because the parties and causes of action were substantially the
same. The CA held that there was no new evidence presented that could change the previous
ruling.
ISSUES:
Whether or not the petitioners can challenge the validity of Original Certificate of Title (OCT)
No. 4216 despite a prior Supreme Court decision that already conclusively settled the same issue.
RULING:
No, the petitioners cannot challenge the validity of Original Certificate of Title (OCT) No. 4216
because a prior Supreme Court decision has conclusively settled the same issue.
The doctrine of conclusiveness of judgment, a component of res judicata, dictates that a
judgment in a prior case operates as an estoppel as to the matters actually determined in that case
or necessarily included therein. Once a case has been decided one way, another case involving
exactly the same point at issue should be decided in the same manner.
In the case at bar, the Supreme Court considered the final appeal made by the petitioners. The
Court affirmed the decisions of the lower courts. It stressed the doctrine of res judicata,
explaining that the Margolles case had already settled the issue of OCT No. 4216's validity. The
Court noted that even though there was no absolute identity of parties, there was a substantial
identity of interests between the present case and the Margolles case. The Court held that the
principle of conclusiveness of judgment barred the petitioners from re-litigating the same issue.
Additionally, the Court pointed out that no new evidence was presented that was not considered
in the Margolles case, making it appropriate to uphold the validity of OCT No. 4216.
Thus, the doctrine of conclusiveness of judgment barred the petitioners from re-litigating the
same issue, and the validity of OCT No. 4216 should not be disturbed.