SUBJECT TOPIC DATE MADE DIGEST MAKER

ITL Res Judicata July 26, 2019 H. Sajonia

CASE NAME: Republic of the Phils. Vs. YU

PONENTE: Quisimbing, J.

CASE SUMMARY:

RULE OF LAW:

DETAILED FACTS

-In Valdehueza vs. Republic, expropriation of Lot No. 939 in Lahug, Cebu City affirmed.
Valdehueza is not entitled to recover the land but only to demand fair market value.

- In Yu vs. Republic, CA annulled sale of lot by Valdehueza to Ramon Yu and held that the
latter was not a purchaser in good faith. They did not appeal so judgment became final and
executory.

-Oct 1 1992, respondents filed complaint for reversion of expropriated property. Petitoner,
Republic of the Philippines, denied respondents’ right to reacquire title and ownership on the
ground of res judicata.

-RTC dismissed complaint filed but CA ruled there was not res judicata and remanded the
case to the trial court.

-Petition for Review on Certiorari of a decision of the CA.

ISSUE Analysis

W/N The reversion of Petitioner (Republic)- ​RTC properly dismissed complaint on the
expropriated property is grounds of res judicata.
barred on the ground of
Res Judicata (YES) - Sale in Yu’s favor invalidated in Yu vs. Republic
- Expropriation absolute and final

Respondent (Yu)- ​Action is not barred by res judicata because

abandonment of gov’t for public purpose constitutes a new cause
of action.

(Obiter)
Res Judicata- a matter adjudged; a thing judicially acted upon or
 decided.

4 elements of Res judicata:

1. Judgment sought to bar new action must be final
2. Decision must have been rendered by a court having
jurisdiction over the subject matter and parties.
3. Disposition of the case must be on the merits
4. There must be identity of parties, subject matter, and
causes of action.

2 concepts of res judicata:

1. Bar by prior judgment
- There is identity of parties
- Subject matter
- Cause of action , in the first case as in the second

2. Conclusiveness of judgment
- There is identity of parties and subject matter
- No/different cause of action

Doctrine of Conclusiveness of Judgment: facts and issues

actually and directly resolved in a former suit cannot again be
raised in any future case between the same parties, even if the
latter suit may involve a different claim or cause of action.

HOLDING

Conclusiveness of judgment exists in the present case since respondents seek to enforce a
right based on a sale which has been nullified by a final and executory judgment. (The
validity of the sale which has already been decided in the case of Valdehueza vs. Republic)

RULING

Petition is GRANTED. Decision of CA SET ASIDE and RTC decision Affirmed.

OTHER OPINIONS

Carpio, Carpio-Morales and Tinga, JJ. concur.