HACIENDA BIGAA V.

CHAVEZ
G.R. NO. 174160, APRIL 20, 2010
BRION, J

FACTS:
Respondent was charged with ejectment (forcible entry) by petitioner alleging that he
entered the premises of the latter without prior consent by force/stealth and
subsequently built a house on the property and lots covered by TCT Nos. 44695 &
56120. The lots were originally owned by Ayala & Zobel which were covered by TCT
No. 722. They expanded their lot adding 2,000 hectares of land. Afterwards they
ordered the subdivision of lots and sold it to third parties. The Republic leased out
portions of the aforementioned lands to fishpond permittees approved through the
Bureau of Fisheries. It then gave rise to dispute between the owners of Hacienda
Calatagan and their privies and/or successors-in-interest and the Republic or its lessees
or fishpond permittees. Backtracking the forcible entry case, then defendant Chavez
alleged in his answer that his mother was a fishpond permittee/lessee under the Bureau
of Fisheries occupying the same parcels of land as Zoila's successor-in-interest which
Hacienda Bigaa also claims. Chavez argued that the suit is barred by prior judgment in
two prior cases which are a suit for unlawful detainer filed by the Zobels against his
mother before the JP Court of Calatagan; and a case of accion reinvindicatoria filed by
the Republic, Zoila de Chavez, and other lessees or fishpond permittees of the
Republic, against Zobel before the CFI of Batangas. Then asserting that the rulings in
these two cases, therefore constitute res judicata with respect to the present case. The
MTC stressed that the titles of Hacienda Bigaa were among the "other subdivision titles"
declared void in the case of Ayala y Cia as areas not legitimately covered by TCT No.
722 and which are therefore part of the public domain. As ordered in the three
antecedent cases of Dizon, Ayala y Cia, and De los Angeles, they should revert to the
Republic. MTC ruled that the elements of res judicata are present. RTC and CA
affirmed in toto the appealed decision.

ISSUE:
Whether or not there is res judicata

RULING:
Yes. The SC rejected Hacienda Bigaa's position that there could be no res judicata in
this case because the present suit is for forcible entry while the antecedent cases
adverted were based on different causes of action – i.e., quieting of title, annulment of
titles and accion reinvindicatoria. For, res judicata, under the concept of conclusiveness
of judgment, operates even if no absolute identity of causes of action exists. Res
judicata, in its conclusiveness of judgment concept, merely requires identity of issues.