Yulo v. Yang
REITERATIONFacts
The Antecedents: Plaintiffs-appellants, Rosario U. Yulo and Jose C. Yulo, filed a petition to reopen a case, alleging that the relationship between Rosario U. Yulo and defendant-appellee Yang Chiao Seng as lessor and lessee had already been definitively decided by the Court of Appeals in a previous case (Sta. Marina, et al. v. Rosario U. Yulo and Yang Chiao Seng, C.A. G.R. No. 8143-R). Procedural History: The plaintiffs-appellants claimed that the Court of Appeals, in the aforementioned case, had held that the parties were partners in the construction of the Astor Theatre. However, the Court noted that the previous case was an ejectment suit filed by Emilia and Maria Carrion Sta. Marina against Rosario Yulo and Yang Chiao Seng, concerning the reasonable value for the use and occupation of the land. The Court of Appeals in that case had determined that P3,000 represented Rosario U. Yulo's share in the profits of the partnership, not the reasonable rent of the property. The Petition: The present petition sought to reopen the case based on the alleged prior ruling of the Court of Appeals establishing a partnership relationship between Rosario U. Yulo and Yang Chiao Seng.
Issue(s)
Whether the previous decision of the Court of Appeals in Sta. Marina, et al. v. Rosario U. Yulo and Yang Chiao Seng, C.A. G.R. No. 8143-R, constitutes res judicata on the issue of partnership between Rosario U. Yulo and Yang Chiao Seng. Whether the relationship between Rosario U. Yulo and Yang Chiao Seng is that of partners or sublessor and sublessee.
Ruling
The Supreme Court denied the motion to reopen the case and affirmed its previous conclusion that the relationship between Rosario U. Yulo and Yang Chiao Seng is merely that of sublessor and sublessee, not partners. The Court ordered the remand of the record to the court below.
Ratio Decidendi
On the issue of res judicata: The Supreme Court held that no res judicata could be claimed for the previous judgment of the Court of Appeals. The Court explained that for res judicata to apply, there must be an identity of parties, an identity of subject matter, and an identity of cause of action. In the previous case, the parties were Emilia and Maria Carrion Sta. Marina as plaintiffs and Rosario U. Yulo and Yang Chiao Seng as defendants, and the issue decided was the rental value of the property in an ejectment case. In the present case, the action is between Rosario U. Yulo as plaintiff and Yang Chiao Seng as defendant, and the issue is whether the plaintiff is a partner or merely a sublessee. Therefore, there was no identity of parties, nor identity of issue, nor identity of cause of action. On the relationship between the parties: The Supreme Court reiterated its satisfaction with its conclusion that the relationship between plaintiff-appellant Rosario U. Yulo and Yang Chiao Seng is merely that of sublessor and sublessee, and not that of partners. This conclusion was reached after considering the arguments and the nature of the previous case. The Court emphasized that parties to a judgment are not bound by it in a subsequent controversy between each other unless they were adversary parties in the original action, meaning there must have been an issue or controversy between them. The opportunity to litigate against the party seeking to use the judgment is crucial for the doctrine of res judicata to apply.
Main Doctrine
For res judicata to apply, there must be an identity of parties, of subject matter, and of cause of action between the previous and the subsequent suits. A prior judgment between different parties or involving a different issue or cause of action does not bar a subsequent suit.