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SOCIAL SECURITY COMMISSION v. RIZAL POULTRY

This case has been cited 9 times or more.

	GR NOS. 153745-46 2015-10-14	NEMENCIO C. PULUMBARIT v. CA JARDELEZA, J.
In Social Security Commission v. Rizal Poultry and, Livestock Association,[75] we laid down the requirements of res judicata in the concept of "conclusiveness of judgment," to wit: There is "bar by prior judgment" when, as between the first case where the judgment was rendered and the second case that is sought to be barred, there is identity of parties, subject matter, and causes of action. In this instance, the judgment in the first case constitutes an absolute bar to the second action.
	GR No. 209535 2015-06-15	TERESITA S. LEE v. LUI MAN CHONG MENDOZA, J.
Significantly, the elements of res judicata are: (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, and causes of action. Should identity of parties, subject matter, and causes of action be shown in the two cases, then res judicata in its aspect as a “bar by prior judgment” would apply. If as between the two cases, only identity of parties can be shown, but not identical causes of action, then res judicata as “conclusiveness of judgment” applies.[10]
	GR No. 176908 2015-03-25	PURISIMO M. CABAOBAS v. PEPSI-COLA PRODUCTS PERALTA, J.
There is no dispute that the issues, subject matters and causes of action between the parties in Pepsi-Cola Products Philippines, Inc. v. Molon[26] and the present case are identical, namely, the validity of PCPPI's retrenchment program, and the legality of its employees' termination. There is also substantial identity of parties because there is a community of interest between the parties in the first case and the parties in the second case, even if the latter was not impleaded in the first case.[27] The respondents in Pepsi-Cola Products Philippines, Inc. v. Molon[28] are petitioners' former co-employees and co-union members of LEPCEU-ALU who were also terminated pursuant to the PCPPI's retrenchment program. The only difference between the two cases is the date of the employees' termination, i.e., Molon, et al. belong to the first batch of employees retrenched on July 31, 1999, while petitioners belong to the second batch retrenched on February 15, 2000. That the validity of the same PCPPI retrenchment program had already been passed upon and, thereafter, sustained in the related case of Pepsi-Cola Products Philippines, Inc. v. Molon,[29] albeit involving different parties, impels the Court to accord a similar disposition and uphold the legality of same program. To be sure, the Court is well aware of the pronouncement in Philippine Carpet Manufacturing Corporation v. Tagyamon,[30] that: The doctrine though is not cast in stone for upon a showing that circumstances attendant in a particular case override the great benefits derived by our judicial system from the doctrine of stare decisis, the Court is justified in setting it aside. For the Court, as the highest court of the land, may be guided but is not controlled by precedent. Thus, the Court, especially with a new membership, is not obliged to follow blindly a particular decision that it determines, after re-examination, to call for a rectification.
	GR No. 158916 2014-03-19	HEIRS OF CORNELIO MIGUEL v. HEIRS OF ANGEL MIGUEL LEONARDO-DE CASTRO, J.
(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, and causes of action.[36]
	GR No. 172302 2014-02-18	PRYCE CORPORATION v. CHINA BANKING CORPORATION LEONEN, J.
The elements for res judicata to apply are as follows: (a) the former judgment was final; (b) the court that rendered it had jurisdiction over the subject matter and the parties; (c) the judgment was based on the merits; and (d) between the first and the second actions, there was an identity of parties, subject matters, and causes of action.[34]
	GR No. 193493 2013-06-13	JAIME N. GAPAYAO v. ROSARIO FULO SERENO, C.J.
The right of an employee to be covered by the Social Security Act is premised on the existence of an employer-employee relationship.[73] That having been established, the Court hereby rules in favor of private respondent.
	GR No. 166462 2012-10-24	P. L. UY REALTY CORPORATION v. ALS MANAGEMENT VELASCO JR., J.
The Court, in Social Security Commission v. Rizal Poultry and Livestock Association, Inc.,[37] distinguished the two (2) concepts in this wise:Res judicata embraces two concepts: (1) bar by prior judgment as enunciated in Rule 39, Section 47(b) of the Rules of Civil Procedure; and (2) conclusiveness of judgment in Rule 39, Section 47(c).
	GR No. 187122 2012-02-22	NEGROS SLASHERS v. ALVIN L. TENG VILLARAMA, JR., J.
To clarify, res judicata is defined in jurisprudence as to have four basic elements: (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, and causes of action.[27]
	GR No. 163433 2011-08-22	SPS. NELSON R. VILLANUEVA AND MYRA P. VILLANUEVA v. CA PERALTA, J.
The elements of res judicata are: (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, and causes of action.[15][ ]The Court finds that the CA and the RTC did not err in finding that all of the abovementioned elements are present in the instant case.