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GR No. 212277

2015-02-11

PERLAS-BERNABE, J.

Simply stated, a judgment on the merits is one wherein there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter,[42] such as the MCTC-Nabunturan-Mawab's January 24, 2006 Decision which had resolved the substantive issue in Civil Case No. 821 as above-explained. Contrary to respondents' stance,[43] said Decision was not premised on a mere technical ground, particularly, on improper venue. This is evinced by the qualifier "granting arguendo" which opens the discussion thereof, to show that the first ejectment complaint would, according to the MCTC-Nabunturan-Mawab, have been dismissed on improper venue notwithstanding the undated lease contract's simulated character.[44]

GR No. 175799

2011-11-28

NM ROTHSCHILD v. LEPANTO CONSOLIDATED MINING COMPANY

LEONARDO-DE CASTRO, J.

In view of the above, we therefore rule that petitioner, by seeking affirmative reliefs from the trial court, is deemed to have voluntarily submitted to the jurisdiction of said court. A party cannot invoke the jurisdiction of a court to secure affirmative relief against his opponent and after obtaining or failing to obtain such relief, repudiate or question that same jurisdiction.[48] Consequently, the trial court cannot be considered to have committed grave abuse of discretion amounting to lack or excess of jurisdiction in the denial of the Motion to Dismiss on account of failure to acquire jurisdiction over the person of the defendant.

GR No. 170375

2010-07-07

REPUBLIC v. MAMINDIARA P. MANGOTARA

LEONARDO-DE CASTRO, J.

The doctrine of res judicata comprehends two distinct concepts - (1) bar by former judgment, and (2) conclusiveness of judgment. For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action. When there is no identity of causes of action, but only an identity of issues, there exists res judicata in the concept of conclusiveness of judgment. Although it does not have the same effect as res judicata in the form of bar by former judgment which prohibits the prosecution of a second action upon the same claim, demand, or cause of action, the rule on conclusiveness of judgment bars the relitigation of particular facts or issues in another litigation between the same parties on a different claim or cause of action.[148]

GR NO. 167961

2007-04-03

SPS. MANUEL LEY AND JANET LEY v. UNION BANK OF PHILIPPINES

TINGA, J.

For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action.[37]

GR NO. 131191

2006-09-26

FORTUNATA MANUGAS VILLARINO ASSISTED BY HER HUSBAND ROGELIO VILLARINO v. MARY Y. AVILA

TINGA, J.

For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action. When there is no identity of causes of action, but only an identity of issues, there exists res judicata in the concept of conclusiveness of judgment. Although it does not have the same effect as res judicata in the form of bar by former judgment which prohibits the prosecution of a second action upon the same claim, demand, or cause of action, the rule on conclusiveness of judgment bars the relitigation of particular facts or issues in another litigation between the same parties on a different claim or cause of action.[8]

GR NO. 157557

2006-03-10

REPUBLIC v. RAMON YU

At this juncture, we need to stress that res judicata has two concepts: [14] (1) "bar by prior judgment" as enunciated in Rule 39, Section 47 (b) [15] of the Rules of Civil Procedure; and (2) "conclusiveness of judgment" in Rule 39, Section 47 (c) [16].

GR NO. 155698

2006-01-31

PHILIPPINE NATIONAL OIL COMPANY v. NATIONAL COLLEGE OF BUSINESS

QUISUMBING, J.

There is a judgment on the merits when there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter of the case.[22] Note, however, that the root cause of G.R. Nos. 112282 and 107909 concerned a motion for issuance of a writ of possession.

GR NO. 161029

2005-01-19

SPRINGSUN MANAGEMENT SYSTEMS CORPORATION v. OSCAR CAMERINO

SANDOVAL-GUTIERREZ, J.

Likewise, in Sta. Lucia Realty and Development, Inc. vs. Cabrigas,[36] we refused to nullify the proceedings in a case conducted by the trial court even if it has no jurisdiction over the subject matter thereof, considering that the party assailing its jurisdiction is guilty of estoppel, thus:"In the case at bar, it was found by the trial court in its 30 September 1996 decision in LCR Case No. Q-60161(93) that private respondents (who filed the petition for reconstitution of titles) failed to comply with both sections 12 and 13 of RA 26 and therefore, it had no jurisdiction over the subject matter of the case. However, private respondents never questioned the trial court's jurisdiction over its petition for reconstitution throughout the duration of LCR Case No. Q-60161(93). On the contrary, private respondents actively participated in the reconstitution proceedings by filing pleadings and presenting its evidence. They invoked the trial court's jurisdiction in order to obtain affirmative relief the reconstitution of their titles. Private respondents have thus foreclosed their right to raise the issue of jurisdiction by their own actions.

GR No. 139031

2004-10-18

MARIE ANTOINETTE R. SOLIVEN v. FASTFORMS PHILIPPINES

SANDOVAL-GUTIERREZ, J.

Similarly, in the subsequent case of Sta. Lucia Realty and Development, Inc. vs. Cabrigas,[15] we ruled:"In the case at bar, it was found by the trial court in its 30 September 1996 decision in LCR Case No. Q-60161(93) that private respondents (who filed the petition for reconstitution of titles) failed to comply with both sections 12 and 13 of RA 26 and therefore, it had no jurisdiction over the subject matter of the case. However, private respondents never questioned the trial court's jurisdiction over its petition for reconstitution throughout the duration of LCR Case No. Q-60161(93). On the contrary, private respondents actively participated in the reconstitution proceedings by filing pleadings and presenting its evidence. They invoked the trial court's jurisdiction in order to obtain affirmative relief the reconstitution of their titles. Private respondents have thus foreclosed their right to raise the issue of jurisdiction by their own actions.

GR No. 146082

2004-07-30

MELCHOR CUSTODIO v. ROSENDO F. CORRADO

QUISUMBING, J.

In the present case, the judgment in Civil Case No. 116 was not on the merits. A judgment on the merits is one rendered after argument and investigation, and when there is determination which party is right, as distinguished from a judgment rendered upon some preliminary or formal or merely technical point, or by default and without trial.[16] Thus, a judgment on the merits is one wherein there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter of the case.[17] In this case, the MTC's dismissal of Civil Case No. 116 was anchored on its lack of jurisdiction and lack of proof of the date of demand without determining and resolving who has the right of possession between petitioner and respondent. Verily, the case was not resolved on the merits but was dismissed on technical points. A judgment dismissing an action for want of jurisdiction cannot operate as res judicata on the merits.[18]

GR No. 135441

2003-11-20

ROBERTO P. TOLENTINO v. DOLORES NATANAUAN

AUSTRIA-MARTINEZ, J.

The elements of res judicata are: (a) the former judgment must be final; (b) the court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be, between the first and second actions, identity of parties, subject matter, and causes of action.[31]

	GR No. 212277 2015-02-11	ROBERT v. GILBERT PERLAS-BERNABE, J.
Simply stated, a judgment on the merits is one wherein there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter,[42] such as the MCTC-Nabunturan-Mawab's January 24, 2006 Decision which had resolved the substantive issue in Civil Case No. 821 as above-explained. Contrary to respondents' stance,[43] said Decision was not premised on a mere technical ground, particularly, on improper venue. This is evinced by the qualifier "granting arguendo" which opens the discussion thereof, to show that the first ejectment complaint would, according to the MCTC-Nabunturan-Mawab, have been dismissed on improper venue notwithstanding the undated lease contract's simulated character.[44]
	GR No. 175799 2011-11-28	NM ROTHSCHILD v. LEPANTO CONSOLIDATED MINING COMPANY LEONARDO-DE CASTRO, J.
In view of the above, we therefore rule that petitioner, by seeking affirmative reliefs from the trial court, is deemed to have voluntarily submitted to the jurisdiction of said court. A party cannot invoke the jurisdiction of a court to secure affirmative relief against his opponent and after obtaining or failing to obtain such relief, repudiate or question that same jurisdiction.[48] Consequently, the trial court cannot be considered to have committed grave abuse of discretion amounting to lack or excess of jurisdiction in the denial of the Motion to Dismiss on account of failure to acquire jurisdiction over the person of the defendant.
	GR No. 170375 2010-07-07	REPUBLIC v. MAMINDIARA P. MANGOTARA LEONARDO-DE CASTRO, J.
The doctrine of res judicata comprehends two distinct concepts - (1) bar by former judgment, and (2) conclusiveness of judgment. For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action. When there is no identity of causes of action, but only an identity of issues, there exists res judicata in the concept of conclusiveness of judgment. Although it does not have the same effect as res judicata in the form of bar by former judgment which prohibits the prosecution of a second action upon the same claim, demand, or cause of action, the rule on conclusiveness of judgment bars the relitigation of particular facts or issues in another litigation between the same parties on a different claim or cause of action.[148]
	GR NO. 167961 2007-04-03	SPS. MANUEL LEY AND JANET LEY v. UNION BANK OF PHILIPPINES TINGA, J.
For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action.[37]
	GR NO. 131191 2006-09-26	FORTUNATA MANUGAS VILLARINO ASSISTED BY HER HUSBAND ROGELIO VILLARINO v. MARY Y. AVILA TINGA, J.
For res judicata to serve as an absolute bar to a subsequent action, the following requisites must concur: (1) the former judgment or order must be final; (2) the judgment or order must be on the merits; (3) it must have been rendered by a court having jurisdiction over the subject matter and parties; and (4) there must be between the first and second actions, identity of parties, of subject matter, and of causes of action. When there is no identity of causes of action, but only an identity of issues, there exists res judicata in the concept of conclusiveness of judgment. Although it does not have the same effect as res judicata in the form of bar by former judgment which prohibits the prosecution of a second action upon the same claim, demand, or cause of action, the rule on conclusiveness of judgment bars the relitigation of particular facts or issues in another litigation between the same parties on a different claim or cause of action.[8]
	GR NO. 157557 2006-03-10	REPUBLIC v. RAMON YU
At this juncture, we need to stress that res judicata has two concepts: [14] (1) "bar by prior judgment" as enunciated in Rule 39, Section 47 (b) [15] of the Rules of Civil Procedure; and (2) "conclusiveness of judgment" in Rule 39, Section 47 (c) [16].
	GR NO. 155698 2006-01-31	PHILIPPINE NATIONAL OIL COMPANY v. NATIONAL COLLEGE OF BUSINESS QUISUMBING, J.
There is a judgment on the merits when there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter of the case.[22] Note, however, that the root cause of G.R. Nos. 112282 and 107909 concerned a motion for issuance of a writ of possession.
	GR NO. 161029 2005-01-19	SPRINGSUN MANAGEMENT SYSTEMS CORPORATION v. OSCAR CAMERINO SANDOVAL-GUTIERREZ, J.
Likewise, in Sta. Lucia Realty and Development, Inc. vs. Cabrigas,[36] we refused to nullify the proceedings in a case conducted by the trial court even if it has no jurisdiction over the subject matter thereof, considering that the party assailing its jurisdiction is guilty of estoppel, thus:"In the case at bar, it was found by the trial court in its 30 September 1996 decision in LCR Case No. Q-60161(93) that private respondents (who filed the petition for reconstitution of titles) failed to comply with both sections 12 and 13 of RA 26 and therefore, it had no jurisdiction over the subject matter of the case. However, private respondents never questioned the trial court's jurisdiction over its petition for reconstitution throughout the duration of LCR Case No. Q-60161(93). On the contrary, private respondents actively participated in the reconstitution proceedings by filing pleadings and presenting its evidence. They invoked the trial court's jurisdiction in order to obtain affirmative relief the reconstitution of their titles. Private respondents have thus foreclosed their right to raise the issue of jurisdiction by their own actions.
	GR No. 139031 2004-10-18	MARIE ANTOINETTE R. SOLIVEN v. FASTFORMS PHILIPPINES SANDOVAL-GUTIERREZ, J.
Similarly, in the subsequent case of Sta. Lucia Realty and Development, Inc. vs. Cabrigas,[15] we ruled:"In the case at bar, it was found by the trial court in its 30 September 1996 decision in LCR Case No. Q-60161(93) that private respondents (who filed the petition for reconstitution of titles) failed to comply with both sections 12 and 13 of RA 26 and therefore, it had no jurisdiction over the subject matter of the case. However, private respondents never questioned the trial court's jurisdiction over its petition for reconstitution throughout the duration of LCR Case No. Q-60161(93). On the contrary, private respondents actively participated in the reconstitution proceedings by filing pleadings and presenting its evidence. They invoked the trial court's jurisdiction in order to obtain affirmative relief the reconstitution of their titles. Private respondents have thus foreclosed their right to raise the issue of jurisdiction by their own actions.
	GR No. 146082 2004-07-30	MELCHOR CUSTODIO v. ROSENDO F. CORRADO QUISUMBING, J.
In the present case, the judgment in Civil Case No. 116 was not on the merits. A judgment on the merits is one rendered after argument and investigation, and when there is determination which party is right, as distinguished from a judgment rendered upon some preliminary or formal or merely technical point, or by default and without trial.[16] Thus, a judgment on the merits is one wherein there is an unequivocal determination of the rights and obligations of the parties with respect to the causes of action and the subject matter of the case.[17] In this case, the MTC's dismissal of Civil Case No. 116 was anchored on its lack of jurisdiction and lack of proof of the date of demand without determining and resolving who has the right of possession between petitioner and respondent. Verily, the case was not resolved on the merits but was dismissed on technical points. A judgment dismissing an action for want of jurisdiction cannot operate as res judicata on the merits.[18]
	GR No. 135441 2003-11-20	ROBERTO P. TOLENTINO v. DOLORES NATANAUAN AUSTRIA-MARTINEZ, J.
The elements of res judicata are: (a) the former judgment must be final; (b) the court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be, between the first and second actions, identity of parties, subject matter, and causes of action.[31]

STA. LUCIA REALTY v. LETICIA CABRIGAS