United Abangan Clan v. Sabellano-Sumagang
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of a marriage allegedly solemnized on February 18, 1873, between Anastacia Abangan and Raymundo Cabellon. The United Abangan Clan, Inc., claiming to represent Anastacia's collateral relatives and intestate heirs, asserts that Anastacia died single and without issue. Conversely, the respondents, identifying themselves as grandchildren and great-grandchildren of Anastacia and Raymundo, claim to be the legitimate descendants. Procedural History: The controversy originated with a delayed registration of the purported marriage in the Register of Marriages of the City Civil Registrar of Cebu City, initiated by Rolando Cabellon and others, who claimed to be the true legal heirs. Subsequently, the United Abangan Clan filed a petition to cancel this marriage entry. The Regional Trial Court (RTC) dismissed the cancellation petition, citing litis pendentia due to a pending prior case for the judicial declaration of Anastacia's heirs, and also on the grounds of prematurity and failure to exhaust administrative remedies. The Petition: The United Abangan Clan filed a Petition for Review on Certiorari under Rule 45, in relation to Rule 41, Section 2(c) of the Rules of Court, challenging the RTC's resolution that dismissed their petition to cancel the marriage entry. The petitioner argues that the RTC erred in finding litis pendentia, asserting that the prior action for judicial declaration of heirship and the current action for cancellation of a civil register entry involve distinct issues and reliefs, thus a judgment in one would not constitute res judicata in the other.
Issue(s)
Whether the RTC erred in dismissing the petition for cancellation of the marriage entry on the ground of litis pendentia. Whether the RTC erred in dismissing the petition for cancellation of the marriage entry on the ground of prematurity for failure to exhaust administrative remedies.
Ruling
The Supreme Court granted the petition, reversed and set aside the RTC's Resolution, and ordered the remand of the case to the RTC for trial on the merits.
Ratio Decidendi
On the issue of litis pendentia: The Court held that there was no identity and similarity between the first petition (SP. PROC. No. 16171-CEB) for judicial declaration of heirship and the second petition (SP. PROC. No. 16180-CEB) for cancellation of entry in the civil register. The Court explained that an action for declaration of heirship establishes a party's right of succession, while an action for cancellation of entry in the civil register pertains to substantial changes affecting civil status, nationality, paternity, filiation, legitimacy, and the registrability of an event. Because the subject matters and issues in the two actions differ, any decision rendered in one cannot constitute res judicata in the other. The Court reiterated the requisites for litis pendentia: (a) identity of parties, (b) identity of rights asserted and relief prayed for founded on the same facts, and (c) identity of the two cases such that the judgment in one would be res judicata in the other. It emphasized that the crucial consideration is the identity and similarity of the issues under litigation, and that a judgment in the prior action would not be conclusive as to the liability sought to be enforced in the second. The Court cited J. Northcott & Co., Inc. v. Villa-Abrille to underscore that if a final judgment in the prior action would support a plea of res judicata in the second, the suits are identical; otherwise, they are not. The Court found that a judicial declaration of heirship is inconclusive on the fact of occurrence of a registered event, and changes in civil register entries do not settle succession issues. Therefore, the RTC erred in dismissing the petition on the ground of litis pendentia. On the issue of prematurity and failure to exhaust administrative remedies: While the RTC also dismissed the case on the ground of prematurity for failure to exhaust administrative remedies, the Supreme Court's primary focus and ruling were on the erroneous application of litis pendentia. The Court's decision to grant the petition and remand the case for trial on the merits implies that the procedural grounds for dismissal by the RTC were found to be insufficient to prevent a full adjudication of the case, particularly given the distinct nature of the cancellation of entry petition from the heirship proceedings.
Main Doctrine
The requisites for litis pendentia are: (a) the identity of parties, or at least like those representing the same interest in both actions; (b) the identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (c) the identity of the two (2) cases, such that the judgment that may be rendered in the pending case would, regardless of which party is successful, amount to res judicata in the other. An action for judicial declaration of heirship and an action for cancellation of entry in the civil register involve different subject matters and issues, thus, a decision in one cannot constitute res judicata in the other.