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HEIRS OF LATE FAUSTINA ADALID ALSO KNOWN AS CRISTINA ADALID NAMELY ELENA JAMITO v. CA

This case has been cited 6 times or more.

2010-11-15
PERALTA, J.
The doctrine of res judicata is a rule which pervades every well-regulated system of jurisprudence and is founded upon two grounds embodied in various maxims of the common law, namely: (1) public policy and necessity, which makes it to the interest of the State that there should be an end to litigation - republicae ut sit litium, and (2) the hardship on the individual that he should be vexed twice for the same cause - nemo debet bis vexari et eadem causa. A contrary doctrine would certainly subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquility and happiness.[46]
2010-06-29
PERALTA, J.
Further, the RTC held that the case should be dismissed on the ground of res judicata. The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matter and cause of action between the first and second actions.[25]
2008-04-16
YNARES-SATIAGO, J.
A cause of action is an act or omission of one party in violation of the legal right of the other.  Its elements are the following: (1) the legal right of plaintiff; (2) the correlative obligation of the defendant, and (3) the act or omission of the defendant in violation of said legal right.[12]  The existence of a cause of action is determined by the allegations in the complaint.[13]  Thus, in the resolution of a motion to dismiss based on failure to state a cause of action, only the facts alleged in the complaint must be considered.  The test in cases like these is whether a court can render a valid judgment on the complaint based upon the facts alleged and pursuant to the prayer therein.  Hence, it has been held that a motion to dismiss generally partakes of the nature of a demurrer which hypothetically admits the truth of the factual allegations made in a complaint.[14]
2007-06-08
QUISUMBING, J.
...The principle of res judicata may not be evaded by the mere expedient of including an additional party to the first and second action. Only substantial identity is necessary to warrant the application of res judicata. The addition or elimination of some parties does not alter the situation. There is substantial identity of parties when there is a community of interest between a party in the first case and a party in the second case albeit the latter was not impleaded in the first case....[20] In this case, the Register of Deeds, as a party in the second complaint is of no moment as it is merely a nominal party.[21]
2006-07-14
CORONA, J.
The absolute identity of parties is not required for the principle of res judicata to apply.[23] A shared identity of interests is sufficient to invoke the application of this principle.[24] The proscription may not be evaded by the mere expedient of including an additional party.[25] Res judicata may lie as long as there is a community of interests between a party in the first case and a party in the second case although the latter may not have been impleaded in the first.[26]
2006-01-23
YNARES-SANTIAGO, J.
It is to the interest of the public that there should be an end to litigation by the parties over a subject fully and fairly adjudicated. The doctrine of res judicata is a rule which pervades every well-regulated system of jurisprudence and is founded upon two grounds embodied in various maxims of the common law, namely: (1) public policy and necessity, which makes it to the interest of the State that there should be an end to litigation republicae ut sit litium, and (2) the hardship on the individual that he should be vexed twice for the same cause nemo debet bis vexari et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquility and happiness. [29]