Valencia v. Regional Trial Court of Quezon City, Branch 90
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and possession of a Philippine Housing and Homesite Corporation (PHHC) lot, designated as Lot 4, Block E-139, located at No. 83 Mabilis St., Pinyahan, Quezon City. Petitioners, the Valencias, claim they occupied the lot since 1950, built a house thereon, and applied to purchase it from PHHC in 1957. However, PHHC awarded the lot to Jose Balot, a non-occupant. The Valencias contested this award through multiple complaints with PHHC and later filed a civil case seeking annulment of the award. During this litigation, Donelita Carino intervened, claiming to have purchased the Valencias' 'squatter's rights,' and later, Corazon C. Llanes, Donelita's sister-in-law, filed a separate case alleging she purchased the same 'squatter's rights' from Rosa Sabadlan Valencia in 1965. 2. Procedural History: The Valencias' initial complaint with PHHC was dismissed. Their subsequent civil case (Civil Case No. Q-17465) to annul the award to Balot was initially decided in favor of intervenor Donelita Carino by the Regional Trial Court (RTC). However, the Court of Appeals (CA) reversed this, ruling in favor of the Valencias and ordering the cancellation of awards to Balot and Carino, and the issuance of a title to the Valencias. This CA decision was affirmed by the Supreme Court (SC) through denials of petitions for review by both Balot and Carino. Despite the finality of this judgment, execution was delayed by further legal actions, including a clarifying resolution from the CA ordering occupants to vacate, and a petition for certiorari by Jocelyn Catbagan, Donelita's daughter, which was also dismissed by the SC. Subsequently, Corazon C. Llanes filed a new case (Civil Case No. Q-43239) with the RTC, claiming ownership based on her alleged purchase of 'squatter's rights' from Rosa Sabadlan Valencia. The RTC admitted Llanes' amended complaint and issued a preliminary injunction, preventing the execution of the earlier final judgment. The Valencias petitioned the CA, which initially ruled in their favor, annulling the RTC's orders. However, upon Llanes' motion for reconsideration, the CA amended its decision, finding res judicata inapplicable due to alleged differences in parties and causes of action. 3. The Petition: The petitioners, the Valencias, seek review of the Court of Appeals' Amended Decision, which reversed its original ruling and found res judicata inapplicable to Civil Case No. Q-43239. The Valencias argue that the action filed by Corazon C. Llanes is barred by the prior judgment in Civil Case No. Q-17465, which had been affirmed by the Supreme Court. They contend that there is substantial identity of parties and causes of action, and that the issues raised by Llanes were already actually and directly controverted and determined in the prior case. The Valencias also question the RTC's grave abuse of discretion in not resolving their motions to dismiss and in issuing injunctive orders that prevented the execution of the final judgment. They pray for the reinstatement of the CA's original decision, the dismissal of Civil Case No. Q-43239, and the lifting of the preliminary injunction, to allow the execution of the long-standing final judgment in their favor.
Issue(s)
Whether Civil Case No. Q-43239 is barred by the prior judgment in Civil Case No. Q-17465 under the principle of res judicata. Whether the Presiding Judge of RTC, Branch 90, committed grave abuse of discretion in not resolving the motions to dismiss filed by the Valencias in Civil Case No. Q-43239.
Ruling
The Supreme Court SET ASIDE the Amended Decision of the Court of Appeals and REINSTATED its original Decision. Civil Case No. Q-43239 of the Regional Trial Court of Quezon City, Branch 90, is ordered DISMISSED, and the Writ of Preliminary Injunction issued therein is ordered LIFTED. The final judgment in CA-G.R. No. 65912-R, dated 29 December 1981, is now executable.
Ratio Decidendi
On the issue of res judicata: The Court found that the principle of res judicata applies to Civil Case No. Q-43239. While there may not be absolute identity of parties, there is substantial identity. Corazon C. Llanes, claiming to have purchased Rosa Sabadlan Valencia's 'squatter rights,' shares an identity of interest with Donelita J. Carino, who made a similar claim in the prior case. Both sought to be declared owners of the same property based on the same alleged purchase, making them privies-in-law. The Court cited Santos vs. Gabriel and Angat vs. Court of Appeals for the principle of substantial identity of parties. The Court held that there is substantial identity of cause of action. The cause of action in both cases stems from the alleged sale of Rosa Sabadlan Valencia's 'squatter rights' to the respective claimants, leading to a claim of ownership over the same Litigated Lot. The Court applied the test of inconsistency: a judgment in favor of Llanes would be inconsistent with the prior judgment declaring the Valencias as owners. The Court emphasized that parties cannot escape the effect of res judicata by varying the form of action or method of presentation, citing Ramos vs. Pangasinan. Even if identity of cause of action were lacking, the doctrine of conclusiveness of judgment applies. The prior judgment in CA-G.R. No. 65912-R had already categorically declared the Valencias entitled to the Litigated Lot and ruled on the invalidity of any alleged sale of 'squatter rights.' This ruling on the invalidity of the sale is conclusive and covers all alleged sales, including that to Llanes, due to the preferential rights of bona fide occupants. The Court cited Comilang vs. Court of Appeals. The Court noted that a prior IAC Resolution explicitly declared the present occupants as 'illegal squatters' and ordered them to vacate in favor of the Valencias. This ruling encompasses Llanes, who was admittedly an occupant. Therefore, Llanes is estopped by matter of record from asserting the same allegations again, as the issues were actually and directly controverted and determined in the first case, citing Machoca vs. Carriage. On the issue of grave abuse of discretion: The Court found that the RTC, Branch 90, exceeded its jurisdiction in issuing a writ of preliminary injunction and status quo orders that prevented the execution of a final judgment from another branch of equal jurisdiction, citing Luciano vs. Provincial Governor and Calderon vs. Gomez. While the RTC's deferment of the motions to dismiss was not necessarily grave abuse of discretion, the prolonged litigation and delay in execution warranted the Supreme Court's intervention to grant the motions and dismiss the case.
Main Doctrine
The principle of res judicata, specifically the requisites of identity of parties and cause of action, should be applied liberally to prevent multiplicity of suits and ensure the finality of judgments, even if there is only substantial, not absolute, identity. A subsequent suit that raises issues already actually and directly controverted and determined in a prior case, even if framed differently, is barred.