Lugayan v. Tizon
REITERATIONFacts
The Antecedents: Civil Case No. 146786-CV for sum of money was filed by Travel 2000 International against Aida Lugayan. Aida failed to file an answer, was declared in default, and was held liable for US$8,430.00. Upon finality, a writ of execution was issued, and Aida's house and lot were levied upon and sold at auction to spouses Tizon, who became the registered owners. Procedural History: Aida filed a complaint for annulment of the MeTC Decision in Civil Case No. 146786-CV, docketed as Civil Case No. 96-79181. Meanwhile, Aida failed to redeem her property, prompting spouses Tizon to file an illegal detainer case (Civil Case No. 5081) against Aida's siblings, Rona and Arturo Lugayan, and all persons claiming rights under them. Aida and another sibling, Diosdado Lugayan, intervened as volunteer defendants, alleging litis pendentia and forum shopping due to the pendency of the annulment case. The MeTC ruled in favor of spouses Tizon, ordering the defendants to vacate the premises and pay damages. The RTC affirmed the MeTC Decision. The Court of Appeals denied the Lugayans' petition for review. The Petition: The Lugayans filed a petition for review on certiorari with the Supreme Court, assailing the Court of Appeals' Decision and alleging that the Court of Appeals erred in not dismissing the unlawful detainer complaint on the grounds of res judicata and forum shopping.
Issue(s)
Whether the Court of Appeals erred in not dismissing the complaint for unlawful detainer on the ground of res judicata. Whether the Court of Appeals erred in not dismissing the complaint for unlawful detainer on the ground of forum shopping.
Ruling
The petition is DENIED. The Decision of the Court of Appeals in CA-G.R. SP No. 61474 is AFFIRMED. Costs against petitioners.
Ratio Decidendi
On the issue of res judicata: The Court held that the fourth element of res judicata, which is the identity of parties, subject matter, and causes of action, was not present. In the first case (Civil Case No. 146786 for sum of money), the parties were Travel 2000 International and Aida Lugayan. In the second case (Civil Case No. 5081 for illegal detainer), the parties were spouses Tizon and Rona and Arturo Lugayan. Furthermore, the subject matter of the first case was non-payment of debt, while the subject matter of the second case was unlawful possession of the property. The causes of action were also different: one was for a sum of money, and the other was for illegal detainer. Therefore, the judgment in the sum of money case could not amount to res judicata in the illegal detainer case. On the issue of forum shopping: The Court reiterated that forum shopping may only exist where the elements of litis pendentia are present or where a final judgment in one case will amount to res judicata in the other. Since neither litis pendentia nor res judicata was found to be present in this case, the Court concluded that there was no forum shopping. The Court found no reversible error of law committed by the Court of Appeals in its assailed decision.
Main Doctrine
There is no res judicata or forum shopping when the elements of identity of parties, subject matter, and causes of action are not present between the two cases.