Magdangal v. City of Olongapo
REITERATIONFacts
The Antecedents: Petitioners, who had constructed improvements on Lot 21 within the National Park Reservation in Olongapo City, are challenging the constitutionality of Batas Pambansa Blg. 875. This law excluded Lot 21 from the reservation and ceded its ownership and possession to the City of Olongapo for the development of a cultural, trade, and tourism center. Procedural History: This is not the first legal challenge to Batas Pambansa Blg. 875 by the petitioners. Previously, in G.R. No. 62784, their petition for declaratory relief was dismissed without prejudice to filing in the proper forum. Subsequently, in G.R. No. 71362, a petition challenging the constitutionality of the same law was filed and dismissed by this Court for lack of merit, after considering the petition and the respondents' comment. The Petition: The current petition, filed by the same individuals who were petitioners in G.R. No. 71362, seeks a writ of prohibition. They are again assailing the constitutionality of Batas Pambansa Blg. 875, arguing that it impairs the obligation of contracts and constitutes deprivation of property without due process of law. However, the Court finds that all the requisites for res judicata are present, as the fundamental cause of action and the subject matter are identical to those in the prior dismissed case.
Issue(s)
Whether the present petition for prohibition is barred by the rule of res judicata in view of the prior dismissal of G.R. No. 71362 for lack of merit.
Ruling
The Court Resolved to DISMISS the present petition.
Ratio Decidendi
On Issue 1: The Court held that all the requisites for the application of res judicata are present. First, the judgment in G.R. No. 71362 is final and undisputed. Second, the Court's jurisdiction over the constitutional issue and the parties in the prior case was clear. Third, the Court clarified that a resolution dismissing a petition for 'lack of merit' is a judgment on the merits, even if it is only a minute resolution, as held in Sy v. Tuvera. Fourth, there is a clear identity of parties, subject matter, and cause of action between G.R. No. 71362 and the present case. The Court emphasized that a party cannot escape the application of res judicata by simply varying the form of action from declaratory relief to prohibition when the fundamental cause of action remains the same. Consequently, the square raising of the constitutionality of Batas Pambansa (B.P.) Blg. 875 in the previous case bars its re-litigation in the present action.
Main Doctrine
The doctrine of res judicata provides that a final judgment on the merits by a court of competent jurisdiction is conclusive of the rights of the parties in all later suits on points and matters determined in the former suit. For the doctrine to apply, four requisites must concur: (a) the former judgment must be final; (b) it must be rendered by a court having jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be identity of parties, subject matter, and cause of action. Crucially, a minute resolution dismissing a petition for 'lack of merit' is considered a judgment on the merits for purposes of res judicata.