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No.

Case Title Part Topic w/ Definition Cause of Action SC HELD/RATIO Judgement


1 Manalang vs Rickards, Basic Legal Interlocutory order - An order is Manalang petitioned the dismissal of his It can be seen from the foregoing that the issues presented in the ejectment proceedings were not settled, said actions It appears that the actions for ejectment were filed before the enactment of Republic Act No. Wherefore, and acting merely
G.R. No. L-11986 July 31, Terms interlocutory when it does not terminate or motion to prohibit the MTC in resuming the having been merely suspended, and the jurisdiction of the court over said proceedings not having been assailed, the 1162 and conceivably under the general principle that laws can only be enforced on the question of procedure
1958 finally dispose of the case, because it leaves hearing for merits of ejectment case filed by
said court has the power to reopen the same for trial on the merits in order that the rights of the parties therein could prospectively, the Municipal Judge for one reason or another saw it fit to suspend the proceedings for submitted to Us by the instant
something to be done by the court before the Rickards, by RTC on the grounds that MTC's
case is finally decided on the merits. July 1954 order was merely interlocutory in be finally determined. quite a long period, probably with the expectation that the question of the constitutionality of Republic appeal, We have to affirm, as
nature Act No. 1162 might be in the meantime duly passed upon. We do hereby affirm, the order
In the case at bar, considering that the dispositive part of the order merely suspended the proceedings of the lower Court dismissing
without touching on the merits of the case or disposing of the issues involved therein , said order cannot appellant’s petition for
be said to be final in character but clearly an interlocutory one which in this case cannot be the subject of an action certiorari and prohibition.
for certiorari. Without pronouncement as to
costs. It is so ordered.

2 J.M. Tuason Co. Inc. vs. Stare decisis et non quita movere - Stand JM Tuason Inc petitioned the RTC's order The Court noted that the supposed irregularities in the land registration proceedings were the same issues raised in Considering the governing principle of stare decisis et non quieta movere (follow past precedents and do Finding the petition for
Hon. Herminio C. Mariano by the decisions and disturb not what is settled. to present in court the registry of deeds and the civil cases decided by Judge Eulogio Mencias. In those case, Judge Mencias ruled that OCT NO.735 was invalid. not disturb what has been settled) it becomes evident that respondents Aquial and Cordova cannot certiorari and prohibition to be
et.al, G.R. No. L-33140 plan of land of OCT 735 to determine if
On appeal to the Supreme Court, that decision was reveresed, and the validity of OCT NO.735 was once more maintain their action in Civil Case No. 8943 without eroding the long settled holding of the courts that meritorious, the trial court is
October 23, 1978 included therein the claimed land by Aquial
sisters that was allegedly included due to upheld. OCT No. 735 is valid and no longer open to attack. " directed to dismiss Civil Case
irregularities in land registration proceeding No. 8943 with prejudice and
"It is against public policy that matters already decided on the merits be relitigated again and again, without costs. No costs
consuming the courts' time and energies et the expense of other litigants: Interest rei publicae ut finis sit
litium."

3 Urbana Velasco Aroc vs Res judicata - A doctrine which precludes Urbana Aroc petitioned the RTC'dismissal Considering now the cause of action in the first case and the cause of action in the second case, the conclusion is There is merit to the claim of the appellant that the legality of the award and sale of the lot in WHEREFORE, the order
People’s Homesite and parties from re-litigating issues actually litigated of her civil case, in where she claims to be inevitable that one is different from the other; that they are not one and the same cause of action: controversy was not directly litigated in the first case not only because the defendant therein did not appealed from by the Court of
Housing Corporation, G.R. and determined by prior and final judgment. the bonafide owner of land sold by PHHC to
appear at the trial to adduce evidence, but also because the PHHC, the grantor and vendor of the First Instance of Rizal in Civil
No. L-39674. January 31, Garcia, despite the latter's disqualification
The requisites for a judgment to be in res to buy said lot, on the grounds of res The first seeks only to remove the cloud on the title of the land. property, was not impleaded as a party litigant in the case. Case No. Q- 11807 dated
1978. The second seeks not only the nullification of the award and sale to the awardee, the cancellation of the Certificate of February 19, 1970 is hereby
judicata are— judicata or barred by the decision on the
(1) The judgment must be final and executory quiet title civil case by Garcia decided in his Title, but also places in issue the power and authority of the grantor (PHHC) to make the award and sell the land to It is also a general rule that a judgment in an action to quiet title is not conclusive as to matters not in reversed and the records
and not merely interlocutory; favor, making him the true owner of the one disqualified to purchase the same, the awardee being a Colonel in the Armed Forces of the Philippines,as issue and determined particularly where such matters could not have been determined in such action. remanded to the said court for
(2) The judgment must have been rendered by a claimed lot. admitted by the PHHC. The qualification of the purchaser is likewise placed in issue. These issues are more basic and further proceedings. No costs.
court having jurisdiction over the subject
fundamental than the quieting of the title and the removal of the cloud on such title. Since the power or authority of the PHHC was not in issue in the first case to quiet title, and neither was
matter and parties and nature of the suit;
(3) The judgment must be on the merits, or at the qualification of the awardees, the plaintiff therein, directly determined the judgment in said case is
least have the effect of an adjudication on the Applying the test accordingly, We hold that the evidence needed to prove the allegations of the second not conclusive and binding in the pre. sent case for annulment of the award and sale, and the
merits; and cause of action must necessarily be more than that in the first case for in the herein second case, cancellation of the title of the awardees or purchaser.
(4) There must be between the first and second additional evidence must be adduced to prove that the PHHC acted in violation of its charter..
actions, identity of parties, of subject matter, or
causes of action, or, in certain cases, reliefs
prayed for.

4 Cayana vs. Court of Res judicata not applicable: Conclusiveness of Cayana et al petitioned CA's reversal of RTC The trial court and the appellate court both erred in the manner by which they treated and applied the final decision Nonetheless, the trial court and the Court of Appeals should have applied the doctrine of conclusiveness WHEREFORE, the Decision
Appeals, G.R. NO. 125607 - Judgement order in 15937 (wherein rtc recognizing the in Civil Case No. 15298 to the instant case. of judgment. and Resolution of the Court of
March 18, 2004 final decision in 15928 ruled this case in
xxx conclusiveness of judgment-states that a fact or question which was in issue in a Appeals are hereby REVERSED
their favor) and upheld the validity of the
deeds of sale which was already declared We find that the evidence required to prove the allegations in Civil Case No. 15937, which involves the former suit and there was judicially passed upon and determined by a court of competent and the Decision of the trial
null in 15298. annulment of the subsequent transactions and TCTs covering the subject parcels of land and the recovery of jurisdiction, is conclusively settled by the judgment therein as far as the parties to that court is accordingly
possession thereof on the basis of the alleged deed of donation inter vivos, is necessarily more than that action and persons in privity with them are concerned and cannot be again litigated in any REINSTATED but with the
required in Civil Case No. 15298, which involves only the annulment of the Deeds of Absolute Sale in favor of future action between such parties or their privies, in the same court or any other court of concurrent modification that the First and
Pastor Cayabyab and the corresponding TCTs covering the First and Second Parcels. Furthermore, the decision in jurisdiction on either the same or different cause of action, while the judgment remains unreversed by Second Parcels should be
Civil Case No. 15298 necessarily turned only upon whether the Deeds of Absolute Sale were fictitious or simulated, proper authority. included in the estate of
while that in Civil Case No. 15937 will also have to include a determination of the good or bad faith of the subsequent Raymundo and Eulalia
purchasers. Res judicata, therefore, does not apply. It has been held that in order that a judgment in one action can be conclusive as to a particular matter in Cayabyab and partitioned in
another action between the same parties or their privies, it is essential that the issue be identical. accordance with the law on
The appellate court's pronouncement that "the decision in Civil Case No. 15298 which declares null and void the If a particular point or question is in issue in the second action, and the judgment will depend on the succession.
deeds of absolute sale dated May 13, 1965 and March 20, 1976 and the corresponding TCT is not conclusive upon the determination of that particular point or question, a former judgment between the same parties
action in Civil Case No. 15937" [33] is, therefore, flawed. It is likewise utterly erroneous for the appellate court to or their privies will be final and conclusive in the second if that same point or question
have disregarded the final judgment in Civil Case No. 15298 declaring null and void the Deeds of Absolute Sale in was in issue and adjudicated in the first suit. Identity of cause of action is not required
favor of Pastor Cayabyab and the corresponding TCTs covering the two parcels of land. It is axiomatic that decisions but merely identity of issues.[32] Under the doctrine of conclusiveness of judgment, the final
which have long become final and executory cannot be annulled by courts and the appellate court is deprived of decision in Civil Case No. 15298 declaring null and void the Deeds of Absolute Sale in favor of Pastor
jurisdiction to alter the trial court's final judgment.[34] Cayabyab and the corresponding TCTs covering the subject parcels of land precluded the Court of
Appeals from further adjudicating on the validity of the said deeds and titles.
The Court holds that the First and Second Parcels properly belong to the estate of Raymundo and Eulalia Cayabyab,
the same to be partitioned in accordance with the law on succession.

5 Gerona et al. v. Secretary Stare decisis - The doctrine that, when the Gerona et al petitioned RTC's dismissal of In conclusion we find and hold that the Filipino flag is not an image that requires religious veneration; rather it is a
In requiring school pupils to participate in the flag salute, the State thru the Secretary of Education was In view of the foregoing, the
of Education, G.R. No L- court has once laid down a principle of law as their motion to dismiss the Sec of symbol of the Republic of the Philippines, of sovereignty, an emblem of freedom, liberty and national unity; that the not imposing a religion or religious belief or a religious test on said students. It was merely appealed decision is affirmed.
13954 applicable to a certain state of facts, it will Education's decision to expell their children
flag salute is not a religious ceremony but an act and profession of love and allegiance and pledge of loyalty to the enforcing a non-discriminatory school regulation applicable to all alike whether The writ of preliminary
adhere to that principle and apply it to all future for not attending the flag ceremony in the
cases where the facts are substantially the same, exercise of their right of religion and prayed fatherland which the flag stands for; Christian, Moslem, Protestant or Jehovah's Witness. The State was merely carrying out the duty injunction heretofore issued is
regardless of whether the parties and property for preliminary injunction and declaration imposed upon it by the Constitution which charges it with supervision over and regulation of all ordered dissolved. No costs.
are the same. of DO 8 unconstitutional that by authority of the legislature, the Secretary of Education was duly authorized to promulgate Department Order educational institutions, to establish and maintain a complete and adequate system of public education,
No. 8, series of 1955; that the requirement of observance of the flag ceremony or salute provided for in said and see to it that all schools aim to develop among other things, civic conscience and teach the duties of
State decisis simply declares that, for the sake of Department Order No. 8, does not violate the Constitutional provision about freedom of religion and citizenship. (Art. XIV, section 5 of the Constitution).
certainty, a conclusion reached in one case
exercise of religion; that compliance with the non-discriminatory and reasonable rules and regulations and school
should be applied to those which follow,
if the facts are substantially the same, discipline, including observance of the flag ceremony is a prerequisite to attendance in public schools; and that for "But between the freedom of belief and the exercise of said belief, there is quite a stretch of road to
even though the parties may be different. failure and refusal to participate in the flag ceremony, petitioners were properly excluded and dismissed from the travel. If the exercise of said religious belief clashes with the established institutions of society and with
public school they were attending. the law, then the former must yield and give way to the latter. The Government steps in and either
But erroneous decisions should not be restrains said exercise or even prosecutes the one exercising it."
perpetuated but is abandoned.
6 Ebralinag v. Division stare decisis - exception: correction of erroneous Ebralinag et al filed these Special civil Exemptions may be accorded to the Jehovah's Witnesses with regard to the observance of the flag ceremony out of "The sole justification for a prior restraint or limitation on the exercise of religious freedom (according WHEREFORE, the petition for
Superintendent of Schools decisions actions for Mandamus, Certiorari and respect for their religious beliefs, however "bizarre" those beliefs may seem to others. Nevertheless, their right not to to the late Chief Justice Claudio Teehankee in his dissenting opinion in German vs. Barangan, 135 SCRA certiorari and prohibition is
of Cebu, 219 SCRA 256 Prohibition alleging that the public
participate in the flag ceremony does not give them a right to disrupt such patriotic exercises. 514, 517) is the existence of a grave and present danger of a character both grave and imminent, of a GRANTED. The expulsion
respondents acted without or in excess of
their jurisdiction and with grave abuse of serious evil to public safety, public morals, public health or any other legitimate public interest, that the orders issued by the public
discretion - (1) in ordering their expulsion We are not persuaded that by exempting the Jehovah's Witnesses from saluting the flag, singing the national anthem State has a right (and duty) to prevent." Absent such a threat to public safety, the expulsion of the respondents against the
without prior notice and hearing, hence, in and reciting the patriotic pledge, this religious which admittedly comprises a "small portion of the school population" petitioners from the schools is not justified. petitioners are hereby
violation of their right to due process, their will shake up our part of the globe and suddenly produce a nation "untaught and uninculcated in and unimbued with ANNULLED AND SET ASIDE.
right to free public education, and their reverence for the flag, patriotism, love of country and admiration for national heroes" (Gerona vs. Sec. of Education, Paraphrasing the warning cited by this Court in Non vs. Dames II, 185 SCRA 523, 535, while the highest The temporary restraining order
right to freedom of speech, religion and
106 Phil. 2, 24). After all, what the petitioners seek only is exemption from the flag ceremony, not exclusion from the regard must be afforded their right to the free exercise of their religion, ""this should not be taken to which was issued by this Court
worship
public schools where they may study the Constitution, the democratic way of life and form of government, and learn mean that school authorities are powerless to discipline them"" if they should commit breaches of the is hereby made permanent.
not only the arts, science, Philippine history and culture but also receive training for a vocation or profession and be peace by actions that offend the sensibilities, both religious and patriotic, of other persons. If they
taught the virtues of "patriotism, respect for human rights, appreciation for national heroes, the rights and duties of quietly stand at attention during the flag ceremony while their classmates and teachers salute the flag,
citizenship, and moral and spiritual values (Sec. 3[2], Art. XIV, 1987 Constitution) as part of the curricula. Expelling sing the national anthem and recite the patriotic pledge, we do not see how such conduct may possibly
or banning the petitioners from Philippine schools will bring about the very situation that this Court had feared in disturb the peace, or pose ""a grave and present danger of a serious evil to public safety, public morals,
Gerona. Forcing a small religious group, through the iron hand of the law, to participate in a ceremony that violates public health or any other legitimate public interest that the State has a right (and duty) to prevent
their religious beliefs, will hardly be condusive to love of country or respect for duly constituted authorities. (German vs. Barangan, 135 SCRA 514, 517)."

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