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GR No. 173636

2016-01-13

HEIRS OF JOSE MA. GEPUELA v. HERNITA MEÑEZ-ANDRES

JARDELEZA, J.

The former concept of res judicata, that is, bar by prior judgment, applies in this case. The following requisites must concur in order that a prior judgment may bar a subsequent action, viz: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action.[56]

GR No. 183350

2012-01-18

PRUDENTIAL BANK v. MAURICIO

VILLARAMA, JR., J.

The doctrine of res judicata thus lays down two main rules which may be stated as follows: (1) The judgment or decree of a court of competent jurisdiction on the merits concludes the parties and their privies to the litigation and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal; and (2) Any right, fact, or matter in issue directly adjudicated or necessarily involved in the determination of an action before a competent court in which a judgment or decree is rendered on the merits is conclusively settled by the judgment therein and cannot again be litigated between the parties and their privies whether the claim or demand, purpose, or subject matter of the two suits is the same or not. These two main rules mark the distinction between the principles governing the two typical cases in which a judgment may operate as evidence. In speaking of these cases, the first general rule above stated, and which corresponds to the aforequoted paragraph (b) of Section 47,[24] is referred to as "bar by former judgment" while the second general rule, which is embodied in paragraph (c) of the same section, is known as "conclusiveness of judgment."[25]

GR No. 186289

2010-06-29

ORIENTAL SHIPMANAGEMENT CO. v. ROMY B. BASTOL

VELASCO JR., J.

Suffice it to say that the July 30, 1999 NLRC Decision cannot and does not constitute res judicata to the instant case. In Estate of the Late Encarnacion Vda. de Panlilio v. Dizon,[51] extensively quoting from the earlier case of Vda. de Cruzo v. Carriaga, Jr.,[52] we explained the nature of res judicata, as now embodied in Sec. 47, Rule 39 of the Rules of Court, in its two concepts of "bar by former judgment" and "conclusiveness of judgment." These concepts of the doctrine of res judicata are applicable to second actions involving substantially the same parties, the same subject matter, and cause or causes of action.[53] In the instant case, there is no second action to speak of, involving as it is the very same action albeit the NLRC remanded it to the Labor Arbiter for further proceedings.

GR No. 141508

2010-05-05

ROBERTO S. BENEDICTO v. MANUEL LACSON

The test to determine identity of causes of action is to ascertain whether the same evidence necessary to sustain the second cause of action is sufficient to authorize a recovery in the first, even if the forms or the nature of the two (2) actions are different from each other. If the same facts or evidence would sustain both, the two (2) actions are considered the same within the rule that the judgment in the former is a bar to the subsequent action; otherwise, it is not. This method has been considered the most accurate test as to whether a former judgment is a bar in subsequent proceedings between the same parties. It has even been designated as infallible.[46]

GR No. 168139

2009-01-20

FERDINAND S. AGUSTIN v. SPS. MARIANO AND PRESENTACION DELOS SANTOS

PUNO, C.J.

We are not unaware of authorities that tend to widen rather than to restrict the doctrine of res judicata for the reason that public interest, as well as private interest, demands an end to litigation as well as the protection of the individual from being vexed twice for the same cause.[38] Indeed, to adhere otherwise 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."[39] However, as in this case, we do not see how untempered overzealousness can help work justice into a situation where an application of the principle of res judicata is clearly not proper.

GR No. 150470

2008-08-06

SPS. FELIPE AND VICTORIA LAYOS v. FIL-ESTATE GOLF

CHICO-NAZARIO, J.

The doctrine of res judicata lays down two main rules which may be stated as follows: (1) The judgment or decree of a court of competent jurisdiction on the merits concludes the litigation between the parties and their privies and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal; and (2) any right, fact, or matter in issue directly adjudicated or necessarily involved in the determination of an action before a competent court in which a judgment or decree 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 claims or demands, purposes, or subject matters of the two suits are the same. These two main rules mark the distinction between the principles governing the two typical cases in which a judgment may operate as evidence.[38] In speaking of these cases, the first general rule above stated, and which corresponds to the afore-quoted paragraph (b) of Section 47, Rule 39 of the Rules of Court, is referred to as "bar by former judgment"; while the second general rule, which is embodied in paragraph (c) of the same section and rule, is known as "conclusiveness of judgment."

GR No. 162868

2008-07-14

RODOLFO D. GARCIA v. PHILIPPINE AIRLINES

REYES, R.T., J.

(c) In any other litigation between the same parties or their successors-in-interest, that only is deemed to have been adjudged in a former judgment which appears upon its face to have been so adjudged, or which was actually and necessarily included therein or necessary thereto. Res judicata has two (2) concepts. The first is "bar by prior judgment" under Rule 39, Section 47(b). This rule dictates that the judgment or decree of a court of competent jurisdiction on the merits concludes the parties and their privies to the litigation and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal.[28] Stated otherwise, the judgment rendered in the first case is an absolute bar to the subsequent action since said judgment is conclusive not only as to the matters offered and received to sustain that judgment but also as to any other matter which might have been offered for that purpose and which could have been adjudged therein.[29]

GR No. 169914

2008-04-18

ASIA'S EMERGING DRAGON CORPORATION v. DEPARTMENT OF TRANSPORTATION

CHICO-NAZARIO, J.

The elements of res judicata, in its concept as a bar by former judgment, are as follows: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action.[46] All of the elements are present herein so as to bar the present Petition.

GR NO. 148777

2007-10-18

ESTATE OF LATE ENCARNACION VDA. DE PANLILIO v. GONZALO DIZON

VELASCO, JR., J.

At bottom, the other elements being virtually the same, the fundamental difference between the rule of res judicata as a bar by former judgment and as merely a rule on the conclusiveness of judgment is that, in the first, there is an identity in the cause of action in both cases involved whereas, in the second, the cause of action in the first case is different from that in the second case.[65] Premised on the foregoing disquisition, the principle of res judicata requires the concurrence of the following requisites:a) The former judgment or order must be final;

GR NO. 142439

2006-12-06

FILINVEST LAND v. ALVAREZ

CHICO-NAZARIO, J.

The following requisites must concur in order that a prior judgment may bar a subsequent action: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action. [31]

GR NO. 142439

2006-12-06

FILINVEST LAND v. ALVAREZ

CHICO-NAZARIO, J.

The only contention between the parties was whether the second requirement, that the decision or order must have been based on the merits of the case, was met. In situations contemplated in Section 3, Rule 17 of the Rules of Court,[36] where a complaint is dismissed for failure of the plaintiff to comply with a lawful order of the court, such dismissal has the effect of an adjudication upon the merits.[37] A dismissal for failure to prosecute has the effect of an adjudication on the merits, and operates as res judicata, particularly when the court did not direct that the dismissal was without prejudice.[38]

	GR No. 173636 2016-01-13	HEIRS OF JOSE MA. GEPUELA v. HERNITA MEÑEZ-ANDRES JARDELEZA, J.
The former concept of res judicata, that is, bar by prior judgment, applies in this case. The following requisites must concur in order that a prior judgment may bar a subsequent action, viz: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action.[56]
	GR No. 183350 2012-01-18	PRUDENTIAL BANK v. MAURICIO VILLARAMA, JR., J.
The doctrine of res judicata thus lays down two main rules which may be stated as follows: (1) The judgment or decree of a court of competent jurisdiction on the merits concludes the parties and their privies to the litigation and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal; and (2) Any right, fact, or matter in issue directly adjudicated or necessarily involved in the determination of an action before a competent court in which a judgment or decree is rendered on the merits is conclusively settled by the judgment therein and cannot again be litigated between the parties and their privies whether the claim or demand, purpose, or subject matter of the two suits is the same or not. These two main rules mark the distinction between the principles governing the two typical cases in which a judgment may operate as evidence. In speaking of these cases, the first general rule above stated, and which corresponds to the aforequoted paragraph (b) of Section 47,[24] is referred to as "bar by former judgment" while the second general rule, which is embodied in paragraph (c) of the same section, is known as "conclusiveness of judgment."[25]
	GR No. 186289 2010-06-29	ORIENTAL SHIPMANAGEMENT CO. v. ROMY B. BASTOL VELASCO JR., J.
Suffice it to say that the July 30, 1999 NLRC Decision cannot and does not constitute res judicata to the instant case. In Estate of the Late Encarnacion Vda. de Panlilio v. Dizon,[51] extensively quoting from the earlier case of Vda. de Cruzo v. Carriaga, Jr.,[52] we explained the nature of res judicata, as now embodied in Sec. 47, Rule 39 of the Rules of Court, in its two concepts of "bar by former judgment" and "conclusiveness of judgment." These concepts of the doctrine of res judicata are applicable to second actions involving substantially the same parties, the same subject matter, and cause or causes of action.[53] In the instant case, there is no second action to speak of, involving as it is the very same action albeit the NLRC remanded it to the Labor Arbiter for further proceedings.
	GR No. 141508 2010-05-05	ROBERTO S. BENEDICTO v. MANUEL LACSON
The test to determine identity of causes of action is to ascertain whether the same evidence necessary to sustain the second cause of action is sufficient to authorize a recovery in the first, even if the forms or the nature of the two (2) actions are different from each other. If the same facts or evidence would sustain both, the two (2) actions are considered the same within the rule that the judgment in the former is a bar to the subsequent action; otherwise, it is not. This method has been considered the most accurate test as to whether a former judgment is a bar in subsequent proceedings between the same parties. It has even been designated as infallible.[46]
	GR No. 168139 2009-01-20	FERDINAND S. AGUSTIN v. SPS. MARIANO AND PRESENTACION DELOS SANTOS PUNO, C.J.
We are not unaware of authorities that tend to widen rather than to restrict the doctrine of res judicata for the reason that public interest, as well as private interest, demands an end to litigation as well as the protection of the individual from being vexed twice for the same cause.[38] Indeed, to adhere otherwise 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."[39] However, as in this case, we do not see how untempered overzealousness can help work justice into a situation where an application of the principle of res judicata is clearly not proper.
	GR No. 150470 2008-08-06	SPS. FELIPE AND VICTORIA LAYOS v. FIL-ESTATE GOLF CHICO-NAZARIO, J.
The doctrine of res judicata lays down two main rules which may be stated as follows: (1) The judgment or decree of a court of competent jurisdiction on the merits concludes the litigation between the parties and their privies and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal; and (2) any right, fact, or matter in issue directly adjudicated or necessarily involved in the determination of an action before a competent court in which a judgment or decree 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 claims or demands, purposes, or subject matters of the two suits are the same. These two main rules mark the distinction between the principles governing the two typical cases in which a judgment may operate as evidence.[38] In speaking of these cases, the first general rule above stated, and which corresponds to the afore-quoted paragraph (b) of Section 47, Rule 39 of the Rules of Court, is referred to as "bar by former judgment"; while the second general rule, which is embodied in paragraph (c) of the same section and rule, is known as "conclusiveness of judgment."
	GR No. 162868 2008-07-14	RODOLFO D. GARCIA v. PHILIPPINE AIRLINES REYES, R.T., J.
(c) In any other litigation between the same parties or their successors-in-interest, that only is deemed to have been adjudged in a former judgment which appears upon its face to have been so adjudged, or which was actually and necessarily included therein or necessary thereto. Res judicata has two (2) concepts. The first is "bar by prior judgment" under Rule 39, Section 47(b). This rule dictates that the judgment or decree of a court of competent jurisdiction on the merits concludes the parties and their privies to the litigation and constitutes a bar to a new action or suit involving the same cause of action either before the same or any other tribunal.[28] Stated otherwise, the judgment rendered in the first case is an absolute bar to the subsequent action since said judgment is conclusive not only as to the matters offered and received to sustain that judgment but also as to any other matter which might have been offered for that purpose and which could have been adjudged therein.[29]
	GR No. 169914 2008-04-18	ASIA'S EMERGING DRAGON CORPORATION v. DEPARTMENT OF TRANSPORTATION CHICO-NAZARIO, J.
The elements of res judicata, in its concept as a bar by former judgment, are as follows: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action.[46] All of the elements are present herein so as to bar the present Petition.
	GR NO. 148777 2007-10-18	ESTATE OF LATE ENCARNACION VDA. DE PANLILIO v. GONZALO DIZON VELASCO, JR., J.
At bottom, the other elements being virtually the same, the fundamental difference between the rule of res judicata as a bar by former judgment and as merely a rule on the conclusiveness of judgment is that, in the first, there is an identity in the cause of action in both cases involved whereas, in the second, the cause of action in the first case is different from that in the second case.[65] Premised on the foregoing disquisition, the principle of res judicata requires the concurrence of the following requisites:a) The former judgment or order must be final;
	GR NO. 142439 2006-12-06	FILINVEST LAND v. ALVAREZ CHICO-NAZARIO, J.
The following requisites must concur in order that a prior judgment may bar a subsequent action: (1) the former judgment or order must be final; (2) it must be a judgment or order on the merits, that is, it was rendered after a consideration of the evidence or stipulations submitted by the parties at the trial of the case; (3) it must have been rendered by a court having jurisdiction over the subject matter and the parties; and (4) there must be, between the first and second actions, identity of parties, of subject matter and of cause of action. [31]
	GR NO. 142439 2006-12-06	FILINVEST LAND v. ALVAREZ CHICO-NAZARIO, J.
The only contention between the parties was whether the second requirement, that the decision or order must have been based on the merits of the case, was met. In situations contemplated in Section 3, Rule 17 of the Rules of Court,[36] where a complaint is dismissed for failure of the plaintiff to comply with a lawful order of the court, such dismissal has the effect of an adjudication upon the merits.[37] A dismissal for failure to prosecute has the effect of an adjudication on the merits, and operates as res judicata, particularly when the court did not direct that the dismissal was without prejudice.[38]

BIENVENIDA MACHOCA ARCADIO VDA. DE CRUZO v. GLICERIO V. CARRIAGA