Dominguez v. De Jesus
REITERATIONFacts
The Antecedents: Roman B. de Jesus, et al. (plaintiffs) filed a complaint against Teodulo Dominguez, et al. (defendants) seeking to be declared absolute owners of certain properties. The case was heard by Judge Filomeno B. Ibañez. Procedural History: Judge Ibañez prepared and signed the decision on March 2, 1953, after his transfer to Zambales, and it was received by the clerk of court in Tarlac on March 6, 1953. On June 24, 1956, the plaintiffs filed a motion for reconsideration, arguing the decision was void as Judge Ibañez was no longer the judge of Tarlac at the time of promulgation. The motion was denied for lack of merit. No appeal was taken from this denial or the original decision, which became final on April 11, 1953. Subsequently, the plaintiffs filed two more actions (Civil Case No. 3086 and Civil Case No. 3196) seeking the same declaration of nullity based on the same grounds. Both subsequent actions were dismissed by the trial court on the ground of res judicata, and no appeals were taken from the dismissal of the first subsequent action. The plaintiffs appealed only the dismissal of the third action. The Appeal: The plaintiffs appealed the dismissal of their third action, assigning as error the trial court's dismissal on the ground of res judicata and its failure to squarely decide the issue of the validity of Judge Ibañez's decision. They contended that the issue of nullity had not been squarely passed upon and decided.
Issue(s)
Whether the plaintiffs are barred by res judicata from filing a third action seeking the declaration of nullity of a decision, after the same issue was raised in a motion for reconsideration in the original case and in a prior subsequent action, both of which were decided adversely to them without appeal. Whether the trial court erred in dismissing the third action on the ground of res judicata without squarely deciding the issue of the validity of the decision.
Ruling
The Supreme Court affirmed the order of dismissal of the trial court, holding that the plaintiffs are barred by the principle of res judicata from raising the issue of the validity of Judge Ibañez's decision.
Ratio Decidendi
On the issue of res judicata and the bar to relitigation: The Supreme Court held that the appellants are barred from raising the issue of the nullity of Judge Ibañez's decision. This is because the issue was already passed upon by the court in Civil Case No. 583 when the appellants filed a motion for reconsideration. Their argument in that motion was disregarded for lack of merit. Instead of appealing the ruling denying their motion for reconsideration, they filed a new case raising the same issue. This second case was decided against them on the ground of res judicata. Undeterred, they filed a third action, reiterating the same issue, and again the court dismissed it on the same ground. The Court emphasized that if the appellants were not agreeable to the ruling on their motion for reconsideration, their proper recourse was to appeal that ruling, not to file a new case. The repeated filing of actions on the same issue, which were consistently decided adversely, clearly demonstrates that the appellants are barred from raising it now under the principle of res judicata. Consequently, the Court is prevented from passing upon the validity of the decision of Judge Ibañez. On the alleged failure of the trial court to squarely decide the issue of validity: The Supreme Court found the contention that the trial court failed to squarely decide the issue of validity to be without merit. The record clearly shows that the issue of nullity was raised by the appellants in their motion for reconsideration in Civil Case No. 583, and their argument was considered and ruled upon, albeit adversely. The subsequent dismissals in Civil Cases Nos. 3086 and 3196 were based on the principle of res judicata, which is a procedural bar arising from the prior adverse rulings on the same issue. Therefore, the trial court did not fail to address the issue; rather, it correctly applied the principle of res judicata to prevent its relitigation.
Main Doctrine
A party is barred by the principle of res judicata from raising an issue that has already been passed upon by the court in a prior motion for reconsideration, from which no appeal was taken. The failure to appeal an adverse ruling on such a motion renders the ruling final and executory, precluding the relitigation of the same issue in a subsequent case.