Sy v. Tuvera
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the award of Lot No. 345, Cadastral No. 85, in Dipolog City. Petitioner Emilio Sy was declared the winning bidder in a public auction sale on March 1, 1960, with a bid of P142,000.00, surpassing private respondent Josefa Vda. de Ramos's bid of P141,000.00. A significant controversy arose regarding the purchase price of the land, with Sy initially securing a reduction, which was later affirmed by the Court of Appeals at the original bid price of P142,000.00. 2. Procedural History: The case traces a complex procedural history involving petitioner's naturalization status and the land award. Initially, Sy's naturalization was granted in 1951 and he took his oath in 1953. However, in 1965, a judge motu proprio sought to nullify the naturalization of several individuals, including Sy. Sy withdrew his subsequent prohibition petition to the Supreme Court and sought to validate his oath, leading to a corrected certificate of naturalization in 1967. Meanwhile, Josefa Vda. de Ramos filed a petition in 1975 with the Office of the President to reopen the land award case, alleging Sy was an alien at the time of bidding. This led to an investigation, a Solicitor General's opinion in 1975 stating Sy was a Chinese citizen in 1960, and an order in 1976 nullifying the award to Sy and granting it to Ramos. Sy appealed to the Office of the President, where the award was initially reversed but then reinstated in favor of Ramos. Sy then elevated the matter to the Supreme Court (G.R. No. 59451), which dismissed his petition with finality. Subsequently, Sy filed a petition for certiorari, prohibition, and mandamus with damages in the Regional Trial Court (Civil Case No. 3561), which was dismissed on grounds of res judicata. This dismissal was affirmed by the Intermediate Appellate Court, leading to the present petition. 3. The Petition: This petition for review on certiorari seeks to set aside the decision and resolution of the Intermediate Appellate Court. Petitioner argues that the Court of Appeals erred in applying the doctrine of res judicata in favor of the private respondent and in relying on the Presidential Executive Assistant Tuvera's decision, which he claims lacked jurisdiction. Petitioner contends that res judicata should apply in his favor, citing previous decisions. He also asserts that the Supreme Court's minute resolutions in G.R. No. 59451 were void for want of jurisdiction and thus could not constitute res judicata, as they allegedly usurped the jurisdiction of lower courts. The Supreme Court, however, found the petition to be a despicable trifling with the administration of justice, an abuse of the right of access to courts, and a waste of judicial resources.
Issue(s)
Whether the Court of Appeals erred in applying the doctrine of res judicata. Whether the Supreme Court's minute resolutions in G.R. No. 59451 constitute res judicata barring Civil Case No. 3561. Whether the February 19, 1981 resolution of Presidential Executive Assistant Tuvera was flawed with lack of jurisdiction.
Ruling
The petition is denied for lack of merit. The decision of the Court of Appeals is affirmed. The instant petition is immediately executory. Treble costs are assessed against the petitioner.
Ratio Decidendi
On the application of res judicata: The Court reiterated the requisites of res judicata: (1) a final former judgment; (2) rendered by a court with jurisdiction over the subject matter and parties; (3) a judgment on the merits; and (4) identity of parties, subject matter, and cause of action. The Court found that the Queto case and CA-G.R. No. 49884-R did not meet these requisites with respect to AC-G.R. SP. No. 04450 due to a lack of identity of parties, subject matter, or cause of action. The Queto case only addressed the jurisdiction of a judge to reopen naturalization proceedings, not the citizenship itself. CA-G.R. No. 49884-R concerned the purchase price of the land, not the validity of the award based on citizenship. On the effect of Supreme Court minute resolutions in G.R. No. 59451: The Court held that the principle of res judicata was correctly applied between G.R. No. 59451 and Civil Case No. 3561. G.R. No. 59451 involved a petition to set aside the same February 19, 1981 resolution of Presidential Executive Assistant Tuvera that was being assailed in Civil Case No. 3561. This petition was dismissed with finality by the Supreme Court on August 8, 1983, and entry of final judgment was made. The Court clarified that even a minute resolution, when it constitutes an adjudication on the merits and becomes final and executory, bars relitigation of the same issues under the rules of res judicata, citing Commercial Union Assurance Company, Limited vs. Lepanto Consolidated Mining Company. The petitioner's argument that the Supreme Court declined jurisdiction and that the minute resolutions were void for want of jurisdiction was rejected as a "patently despicable" attempt to trifle with the administration of justice. On the merits of the February 19, 1981 resolution: The Court stated that the validity, legality, propriety, and correctness of the February 17, 1981 resolution of public respondent Tuvera had already been passed upon with finality by this Court in G.R. No. 59451. Therefore, another review would contravene the rule of res judicata. The petitioner's attempt to have the validity of the Tuvera resolution reviewed by an inferior court after the Supreme Court had already dismissed his petition with finality was deemed an abuse of the right of access to the courts.
Main Doctrine
The doctrine of res judicata applies when there is a final former judgment rendered by a court having jurisdiction over the subject matter and the parties, which is a judgment on the merits, and there is an identity of parties, subject matter, and cause of action between the first and second actions. Minute resolutions of the Supreme Court dismissing a petition for lack of merit, after finality and entry of judgment, constitute a bar to relitigation under res judicata.