Lawyerly

You're currently signed in as:
User

ALADIN CRUZ v. CA AND SPS. LAZARO AND ENRIQUETA VIDAL

This case has been cited 7 times or more.

	GR No. 159691 2013-06-13	HEIRS OF MARCELO SOTTO v. MATILDE S. PALICTE BERSAMIN, J.
In all the five cases (Civil Case No. CEB-24293 included), a n identity of parties existed because the parties were the same, or there was privity among them, or some of the parties were successors-in-interest litigating for the same thing and under the same title and in the same capacity.[15] An absolute identity of the parties was not necessary, because a shared identity of interest sufficed for res judicata to apply.[16] Moreover, mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, would be sufficient.[17] As such, the fact that a previous case was filed in the name of the Estate of Sotto only was of no consequence.
	GR No. 156185 2011-09-12	CATALINA B. CHU v. SPS. FERNANDO C. CUNANAN BERSAMIN, J.
There is identity of parties when the parties in both actions are the same, or there is privity between them, or they are successors-in-interest by title subsequent to the commencement of the action litigating for the same thing and under the same title and in the same capacity.[35] The requirement of the identity of parties was fully met, because the Chus, on the one hand, and the Cunanans, on the other hand, were the parties in both cases along with their respective privies. The fact that the Carloses and Benelda Estate, defendants in Civil Case No. 12251, were not parties in the compromise agreement was inconsequential, for they were also the privies of the Cunanans as transferees and successors-in-interest. It is settled that the absolute identity of parties was not a condition sine qua non for res judicata to apply, because a shared identity of interest sufficed.[36] Mere substantial identity of parties, or even community of interests between parties in the prior and subsequent cases, even if the latter were not impleaded in the first case, was sufficient.[37]
	GR No. 163360 2007-06-08	HEIRS OF IGMEDIO* MAGLAQUE v. CA QUISUMBING, J.
The general rule precluding the relitigation of material facts or questions which were in issue and adjudicated in a former action are commonly applied to all matters essentially connected with the subject matter of the litigation. Thus, it extends to questions necessarily involved in an issue, and necessarily adjudicated or necessarily implied in the final judgment, although no specific finding may have been made in reference thereto, and although such matters were directly referred to in the pleadings and were not actually or formally presented. Under this rule, if the record of the former trial shows that the judgment could not have been rendered without deciding the particular matter, it will be considered as having settled that matter as to all future actions between the parties, and if a judgment necessarily presupposes certain premises, they are as conclusive as the judgment itself. Reasons for the rule are that a judgment is an adjudication on all the matters which are essential to support it, and that every proposition assumed or decided by the court leading up to the final conclusion and upon which such conclusion is based is as effectually passed upon as the ultimate question which is finally solved.[33] The issues on the right of first refusal and fraud in the sale involve matters essentially connected with the subject matter of litigation; hence, preclusion had set in.
	GR No. 157616 2005-07-22	ISIDRO PEREZ v. CA CALLEJO, SR., J.
Indeed, absolute identity of parties is not a condition sine qua non for the application of res judicata. It is sufficient that there is a shared identity of interest.[36] The rule is that, even if new parties are found in the second action, res judicata still applies if the party against whom the judgment is offered in evidence was a party in the first action; otherwise, a case can always be renewed by the mere expedience of joining new parties in the new suit.[37]
	GR No. 152576 2003-05-05	INTRAMUROS ADMINISTRATION v. YVETTE CONTACTO DAVIDE JR., C.J.
Applying our pronouncement in Cruz v. Court of Appeals,[20] the Court of Appeals concluded that the causes of action in Civil Cases Nos. 96-767-44 and 98-90835 are identical because both parties claimed a breach of an obligation under the same lease contract:There is substantial identity in the cause of action in the two cases. Both cases are based on the demand of both parties against each other to perform their obligations under the same contract.
	GR No. 139274 2001-10-23	QUEZON PROVINCE v. ABELIO M. MARTE QUISUMBING, J.
The ultimate test to determine identity of causes of action lies not in the form of an action but on whether the same evidence would support and establish the former and the present causes of action.[11] We find that the instant case meets this test because the same issue of the validity of Titulo de Propriedad No. 4136 remains the issue in the instant case.
	GR No. 136834 2001-08-15	FELIX SENDON v. FRATERNIDAD O. RUIZ QUISUMBING, J.
We also concur with the lower courts' view that there is identity of parties in Civil Case No. 1800 / Civil Case No. K-111 and in the present case, Civil Case No. 3670. For purposes of res judicata, we have held that only substantial identity of parties is required and not absolute identity.[14] 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.[15] In other words, privity or a shared identity of interest is sufficient to invoke application of the principle of res judicata.[16]