Stasa Incorporated v. Court Of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from two ejectment cases filed by Delfin San Jose and later by STASA, Inc. against Mariano Aquino concerning leased premises at 2684 Down, New Panaderos, Sta. Ana, Manila. The initial complaint alleged non-payment of rentals and conversion of the premises from residential to commercial use. Subsequent judgments in these ejectment cases ordered the defendant to vacate and pay rentals. STASA, Inc. later filed a separate complaint for a sum of money against Mariano Aquino and Maria Lourdes Licuanan, seeking to collect unpaid rentals. The defendants argued that this third case was barred by res judicata due to the prior ejectment judgments. 2. Procedural History: Following the ejectment cases, STASA, Inc. filed a complaint for a sum of money (Civil Case No. 83-20734) with the Regional Trial Court (RTC) of Manila, Branch 42, against Mariano Aquino and Maria Lourdes Licuanan. The defendants moved to dismiss, asserting res judicata. The RTC denied this motion in an Order dated September 16, 1985. A subsequent motion for reconsideration filed by Maria Lourdes Licuanan was also denied by the RTC in an Order dated March 7, 1986. Maria Lourdes Licuanan then filed a petition for certiorari and prohibition with the Court of Appeals, challenging the RTC's denial orders. The Court of Appeals granted her petition, reversing the RTC's orders. STASA, Inc. subsequently filed the present petition for review on certiorari with the Supreme Court. 3. The Petition: Petitioner STASA, Inc. seeks reversal of the Court of Appeals' decision, arguing that the appellate court erred in reversing the RTC's orders and dismissing Civil Case No. 83-20734. The petitioner contends that the civil action for a sum of money is distinct from the prior ejectment cases and that private respondent Maria Lourdes Licuanan was not a party in those cases, despite being the actual occupant. Petitioner asserts that Licuanan and Mariano Aquino misrepresented their marital status, hindering the enforcement of the ejectment judgments. Furthermore, petitioner argues that the Court of Appeals erred in concluding that the third case was barred by prior judgment, as there was no identity of parties, subject matter, or cause of action, particularly given Licuanan's non-joinder in the earlier suits.
Issue(s)
Whether the judgment in the previous two ejectment cases would bar the third case for the collection of a sum of money. Whether the Court of Appeals erred in reversing the orders of the trial court and dismissing Civil Case No. 83-20734; and whether Civil Case No. 83-20734 is barred by prior judgment.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals, reinstating the Orders dated September 16, 1985, and March 7, 1986, of the Regional Trial Court of Manila, Branch 42. The case was remanded to the trial court for implementation of the orders.
Ratio Decidendi
On the issue of whether the judgment in the previous two ejectment cases would bar the third case for the collection of a sum of money: The Court held that the principle of res judicata requires four requisites: (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 established facts clearly reveal that there has never been any identity of parties between the two ejectment cases and the case for collection of money. Private respondent herself asserted that she was never impleaded in the ejectment cases nor was she held responsible for the unpaid rentals. The stipulation of facts explicitly stated that private respondent was never made a defendant nor impleaded in Civil Case Nos. 0239933 and 061208-IV, although she was the actual occupant. It cannot be assumed she was impliedly impleaded because she and Mariano Aquino revealed their misrepresentation as lawful husband and wife, thus preventing the enforcement of a writ of execution against a conjugal partnership. The Court cited G. Tractors, Inc. v. Court of Appeals to emphasize that while a wife need not be named to bind the conjugal partnership, a common-law wife must be included to bind her property or make her answerable for liability. Furthermore, the Court cited Martinez v. Court of Appeals, stating that identity of parties requires them to be adversary parties in both cases litigating in the same capacity. Therefore, there is no identity of parties between the ejectment cases and the collection case filed against private respondent. On the issue of whether the Court of Appeals erred in reversing the orders of the trial court and dismissing Civil Case No. 83-20734; and whether Civil Case No. 83-20734 is barred by prior judgment: The Court observed that private respondent and her live-in partner indulged in an orchestrated and manipulative handling of the ejectment cases. They initially posed as a legally married couple but revealed they were not during litigation, possibly to avoid adjudged liability. This scheme was allegedly used to avoid liability, confirmed by the subsequent transfer of properties to private respondent's name, against whom the writ of execution could not be enforced as she was not a party defendant. The Court noted the inconsistency of private respondent's posture in seeking refuge in the principle of 'identity of parties' after attempting to hide her true status when it served her deceitful intention. This manipulation, however, did not alter the legal requirement of identity of parties for res judicata to apply to the collection case.
Main Doctrine
The principle of res judicata requires identity of parties, subject matter, and cause of action. If a party was not impleaded in previous ejectment cases, a subsequent collection case against them for the same rentals is not barred by prior judgment, especially when the previous cases did not establish their liability.