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GR No. 182970

2014-07-23

PERALTA, J.

We disagree. In order for res judicata to bar the institution of a subsequent action, the following requisites must concur: (1) the judgment sought to bar the new action must be final; (2) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be as between the first and second action, identity of parties, subject matter, causes of action as are present in the civil cases below. The foundation principle upon which the doctrine of res judicata rests is that parties ought not to be permitted to litigate the same issue more than once; that when a right or fact has been judicially tried and determined by a court of competent jurisdiction, so long as it remains unreversed, it should be conclusive upon the parties and those in privity with them in law or estate.[27]

GR Nos. 187308 & 187517

2013-09-18

HILARIA BAGAYAS v. ROGELIO BAGAYAS

PERLAS-BERNABE, J.

At the outset, it must be stressed that Civil Case No. 04-42 was a complaint for annulment of sale and partition. In a complaint for partition, the plaintiff seeks, first, a declaration that he is a co-owner of the subject properties; and second, the conveyance of his lawful shares. An action for partition is at once an action for declaration of co-ownership and for segregation and conveyance of a determinate portion of the properties involved.[36] The determination, therefore, as to the existence of co-ownership is necessary in the resolution of an action for partition. As held in the case of Municipality of Biñan v. Garcia:[37]

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. 167000

2011-06-08

GOVERNMENT SERVICE INSURANCE SYSTEM v. GROUP MANAGEMENT CORPORATION (GMC)

LEONARDO-DE CASTRO, J.

It is well-settled that once a judgment attains finality, it becomes immutable and unalterable. It may not be changed, altered or modified in any way even if the modification were for the purpose of correcting an erroneous conclusion of fact or law. This is referred to as the "doctrine of finality of judgments," and this doctrine applies even to the highest court of the land. [82] This Court explained its rationale in this wise: The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality. [83]

GR No. 157717

2011-04-13

DERLA v. HEIRS OF CATALINA DERLA VDA. DE HIPOLITO

LEONARDO-DE CASTRO, J.

Nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. x x x.[59]

GR No. 166988

2009-07-03

HEIRS OF EMILIANO SAN PEDRO v. PABLITO GARCIA

PERALTA, J.

Nothing is more in settled law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of the case.[49]

GR No. 156224

2008-02-19

HEIRS OF PANFILO F. ABALOS v. AURORA A. BUCAL

AZCUNA, J.

Finally, it must be stressed that in a complaint for partition, the plaintiff seeks, first, a declaration that he is a co-owner of the subject properties; and second, the conveyance of his lawful shares. An action for partition is at once an action for declaration of co-ownership and for segregation and conveyance of a determinate portion of the properties involved.[50]

GR No. 158332

2008-02-11

MARICALUM MINING CORPORATION v. REMINGTON INDUSTRIAL SALES CORPORATION

AUSTRIA-MARTINEZ, J.

The foregoing adjudication is conclusive even upon this Court, more so, the CA.[36]

GR NO. 142236

2006-09-27

FILIPRO v. PERMANENT SAVINGS

YNARES-SANTIAGO, J.

Nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case.[21]

AC. NO. 5653

2006-02-27

JOHN SIY LIM v. ATTY. CARMELITO A. MONTANO

CALLEJO, SR., J.

The fact that the parties in the first and second cases are not identical will not prevent the application of the principle of res judicata. Mere substantial identity of parties, or a community of interests between a party in the first case and a party in the subsequent case, even if the latter was not impleaded in the first case, is sufficient.[20] Moreover, a party cannot, by varying the form of action or adopting a different method of presenting his case, escape the operation of the principle that one and the same cause of action shall not be twice litigated between the same parties or their privies.[21] This was what respondent resorted to in order to give some semblance of merit to the complaint for annulment of title. He should have realized that the ruling of the Court in Tuazon v. Court of Appeals[22] effectively determined with finality the rights and obligations of the parties under the questioned deed of sale.

GR NO. 151339

2006-01-31

EDITHA M. FRANCISCO v. ROQUE CO

TINGA, J.

Still, the Court considers the second facet of res judicata, "conclusiveness of judgment" as controlling in this case. Conclusiveness of judgment operates as a bar even if there is no identity as between the first and second causes of judgment. Under the doctrine, any right, fact, or matter in issue 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 the judgment therein and cannot again be litigated between the parties and their privies whether or not the claim, demand, purpose, or subject matter of the two actions is the same.[16]

GR NO. 157605

2005-12-13

SPS. ENRIQUETA RASDAS v. JAIME ESTENOR

TINGA, J.

[C]onclusiveness of judgment states that a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies, in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority. It has been held that in order that a judgment in one action can be conclusive as to a particular matter in another action between the same parties or their privies, it is essential that the issue be identical. If a particular point or question is in issue in the second action, and the judgment will depend on the determination of that particular point or question, a former judgment between the same parties or their privies will be final and conclusive in the second if that same point or question was in issue and adjudicated in the first suit. Identity of cause of action is not required but merely identity of issues.[19] Stated differently, any right, fact, or matter in issue 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 the judgment therein and cannot again be litigated between the parties and their privies whether or not the claim, demand, purpose, or subject matter of the two actions is the same.[20]

GR NO. 153762

2005-08-12

SUSAN HONORIDEZ v. MAKILITO B. MAHINAY

TINGA, J.

Litigation must end and terminate sometime and somewhere, and it is essential to an effective administration of justice that once a judgment has become final the issue or cause involved therein should be laid to rest.[30] This doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice.[31] In fact, nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land.[32] The decision in Civil Case No. CEB-16335 has long become final and executory. This Court finds no reason to disturb the same.

	GR No. 182970 2014-07-23	EMILIANO S. SAMSON v. SPS. JOSE PERALTA, J.
We disagree. In order for res judicata to bar the institution of a subsequent action, the following requisites must concur: (1) the judgment sought to bar the new action must be final; (2) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be as between the first and second action, identity of parties, subject matter, causes of action as are present in the civil cases below. The foundation principle upon which the doctrine of res judicata rests is that parties ought not to be permitted to litigate the same issue more than once; that when a right or fact has been judicially tried and determined by a court of competent jurisdiction, so long as it remains unreversed, it should be conclusive upon the parties and those in privity with them in law or estate.[27]
	GR Nos. 187308 & 187517 2013-09-18	HILARIA BAGAYAS v. ROGELIO BAGAYAS PERLAS-BERNABE, J.
At the outset, it must be stressed that Civil Case No. 04-42 was a complaint for annulment of sale and partition. In a complaint for partition, the plaintiff seeks, first, a declaration that he is a co-owner of the subject properties; and second, the conveyance of his lawful shares. An action for partition is at once an action for declaration of co-ownership and for segregation and conveyance of a determinate portion of the properties involved.[36] The determination, therefore, as to the existence of co-ownership is necessary in the resolution of an action for partition. As held in the case of Municipality of Biñan v. Garcia:[37]
	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. 167000 2011-06-08	GOVERNMENT SERVICE INSURANCE SYSTEM v. GROUP MANAGEMENT CORPORATION (GMC) LEONARDO-DE CASTRO, J.
It is well-settled that once a judgment attains finality, it becomes immutable and unalterable. It may not be changed, altered or modified in any way even if the modification were for the purpose of correcting an erroneous conclusion of fact or law. This is referred to as the "doctrine of finality of judgments," and this doctrine applies even to the highest court of the land. [82] This Court explained its rationale in this wise: The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality. [83]
	GR No. 157717 2011-04-13	DERLA v. HEIRS OF CATALINA DERLA VDA. DE HIPOLITO LEONARDO-DE CASTRO, J.
Nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. x x x.[59]
	GR No. 166988 2009-07-03	HEIRS OF EMILIANO SAN PEDRO v. PABLITO GARCIA PERALTA, J.
Nothing is more in settled law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of the case.[49]
	GR No. 156224 2008-02-19	HEIRS OF PANFILO F. ABALOS v. AURORA A. BUCAL AZCUNA, J.
Finally, it must be stressed that in a complaint for partition, the plaintiff seeks, first, a declaration that he is a co-owner of the subject properties; and second, the conveyance of his lawful shares. An action for partition is at once an action for declaration of co-ownership and for segregation and conveyance of a determinate portion of the properties involved.[50]
	GR No. 158332 2008-02-11	MARICALUM MINING CORPORATION v. REMINGTON INDUSTRIAL SALES CORPORATION AUSTRIA-MARTINEZ, J.
The foregoing adjudication is conclusive even upon this Court, more so, the CA.[36]
	GR NO. 142236 2006-09-27	FILIPRO v. PERMANENT SAVINGS YNARES-SANTIAGO, J.
Nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case.[21]
	AC. NO. 5653 2006-02-27	JOHN SIY LIM v. ATTY. CARMELITO A. MONTANO CALLEJO, SR., J.
The fact that the parties in the first and second cases are not identical will not prevent the application of the principle of res judicata. Mere substantial identity of parties, or a community of interests between a party in the first case and a party in the subsequent case, even if the latter was not impleaded in the first case, is sufficient.[20] Moreover, a party cannot, by varying the form of action or adopting a different method of presenting his case, escape the operation of the principle that one and the same cause of action shall not be twice litigated between the same parties or their privies.[21] This was what respondent resorted to in order to give some semblance of merit to the complaint for annulment of title. He should have realized that the ruling of the Court in Tuazon v. Court of Appeals[22] effectively determined with finality the rights and obligations of the parties under the questioned deed of sale.
	GR NO. 151339 2006-01-31	EDITHA M. FRANCISCO v. ROQUE CO TINGA, J.
Still, the Court considers the second facet of res judicata, "conclusiveness of judgment" as controlling in this case. Conclusiveness of judgment operates as a bar even if there is no identity as between the first and second causes of judgment. Under the doctrine, any right, fact, or matter in issue 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 the judgment therein and cannot again be litigated between the parties and their privies whether or not the claim, demand, purpose, or subject matter of the two actions is the same.[16]
	GR NO. 157605 2005-12-13	SPS. ENRIQUETA RASDAS v. JAIME ESTENOR TINGA, J.
[C]onclusiveness of judgment states that a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies, in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority. It has been held that in order that a judgment in one action can be conclusive as to a particular matter in another action between the same parties or their privies, it is essential that the issue be identical. If a particular point or question is in issue in the second action, and the judgment will depend on the determination of that particular point or question, a former judgment between the same parties or their privies will be final and conclusive in the second if that same point or question was in issue and adjudicated in the first suit. Identity of cause of action is not required but merely identity of issues.[19] Stated differently, any right, fact, or matter in issue 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 the judgment therein and cannot again be litigated between the parties and their privies whether or not the claim, demand, purpose, or subject matter of the two actions is the same.[20]
	GR NO. 153762 2005-08-12	SUSAN HONORIDEZ v. MAKILITO B. MAHINAY TINGA, J.
Litigation must end and terminate sometime and somewhere, and it is essential to an effective administration of justice that once a judgment has become final the issue or cause involved therein should be laid to rest.[30] This doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice.[31] In fact, nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land.[32] The decision in Civil Case No. CEB-16335 has long become final and executory. This Court finds no reason to disturb the same.

ZENAIDA F. DAPAR v. GLORIA LOZANO BIASCAN