Sy Kao v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioners Sy Kao and Chua Lian King, widow and son respectively of the deceased Chua Bing Guan, executed an extrajudicial settlement of his estate, adjudicating all properties to themselves as the sole heirs. This action was taken after the deceased's death on October 29, 1967. The private respondent, Chua Keng Giap, later filed a petition for the settlement of the intestate estate of Chua Bing Guan, alleging he was also a son of the deceased and petitioner Sy Kao. Petitioner Sy Kao denied this, asserting the respondent was the son of different parents. 2. Procedural History: The respondent's petition for settlement of intestate estate was dismissed by the Court of First Instance of Rizal on March 2, 1979, after a ten-year hearing, finding that the respondent was not the son of Sy Kao and the deceased. The respondent's subsequent appeal was dismissed for being out of time, and a petition for mandamus with the Court of Appeals was also dismissed. A petition for certiorari to the Supreme Court (G.R. No. 54992) was likewise dismissed for lack of merit, with subsequent motions for reconsideration also denied. Meanwhile, the respondent filed a new complaint on July 14, 1980, seeking to annul the extrajudicial settlement, alleging preterition and the existence of a will probated during the deceased's lifetime. The petitioners moved to dismiss this complaint based on res judicata, lack of cause of action, and statute of limitations. The respondent court denied the motion to dismiss, and the Court of Appeals affirmed this denial, leading to the instant petition. 3. The Petition: The petitioners, Sy Kao and Chua Lian King, filed this petition for review on certiorari, arguing that the respondent court erred in denying their motion to dismiss the complaint filed by Chua Keng Giap. They contend that the complaint is barred by the doctrine of res judicata, as the issue of whether Chua Keng Giap is a son of the deceased Chua Bing Guan and Sy Kao has already been judicially determined in Special Proceedings No. Q-12592. The petitioners assert that allowing the new complaint would subject them to further litigation on an issue already decided and would violate the principle of conclusiveness of judgment, as provided in Section 49, Rule 39 of the Rules of Court.
Issue(s)
Whether the respondent court erred in denying the motion to dismiss based on the doctrine of res judicata, considering the elements and prior determination of filiation. Whether the respondent's subsequent complaint is barred by a prior judgment, despite the ongoing contest of a will alleged by the respondent.
Ruling
The petition is GRANTED. The orders of the lower court and the Court of Appeals are REVERSED and SET ASIDE. The Regional Trial Court is directed to DISMISS Civil Case No. 30340.
Ratio Decidendi
On the issue of res judicata: The Supreme Court held that the doctrine of res judicata clearly applies to the case at bar. The Court reiterated the elements of res judicata: (1) identity of parties or at least those representing the same interest; (2) identity of rights asserted and reliefs prayed for, founded on the same facts; and (3) identity of the two preceding particulars such that any judgment rendered in the other action will amount to res judicata in the action under consideration. In the earlier Special Proceeding No. Q-12592, both the petitioners and the respondent were parties in their capacity as alleged heirs. The respondent asserted his right over the deceased's property as an alleged son, which was the very basis for instituting both actions. The prior case definitively concluded that the respondent was not a son of the deceased Chua Bing Guan. Therefore, the present complaint, which seeks to annul the extrajudicial settlement based on the same allegation of filiation, directly violates the doctrine of res judicata. Parties should not be permitted to litigate the same issue more than once, and a right or fact judicially tried and determined by a competent court remains conclusive upon the parties. Allowing the parties to proceed with the trial would subject the petitioners to further expense and ordeal, and more importantly, would violate the fundamental principle of res judicata, as provided for in Section 49, Rule 39 of the Rules of Court. The Court found it erroneous for the respondent court not to dismiss the complaint when the ground for dismissal was indubitable. The Court also noted that the will alleged by the respondent was being contested by the petitioners in another case, but this did not alter the applicability of res judicata to the present complaint.
Main Doctrine
The doctrine of res judicata bars a subsequent action if the same parties, asserting the same rights founded on the same facts, have already had their rights judicially tried and determined by a court of competent jurisdiction.