Facts:

The case involves Allied Banking Corporation as the petitioner and Filoteo Alano as the private respondent. The events leading to this case began on May 25, 1987, when the petitioner filed a complaint against several parties, including Alano, in the Regional Trial Court (RTC) of Makati, which was assigned Civil Case No. 16837 (referred to as the First Case). The complaint was based on promissory notes, letters of credit, and trust receipts executed by Dearfield, Incorporated, the principal obligor. On November 16, 1987, Alano filed a motion to dismiss the complaint, arguing that he was not mentioned in the allegations and that the complaint failed to state a cause of action against him. The trial court granted this motion on June 20, 1988, concluding that there was no cause of action against Alano. The petitioner’s motion for reconsideration was denied on September 15, 1988. Subsequently, the petitioner filed a notice of appeal on September 30, 1988, and later an appeal by ce...

Facts:

First Case Initiation

• Petitioner (Allied Banking Corporation) filed a complaint on May 25, 1987, with the Regional Trial Court (RTC) of Makati, initiating Civil Case No. 16837.
• The complaint was based on promissory notes, letters of credit, and trust receipts executed by the principal obligor, Dearfield, Incorporated.
• Several parties, including private respondent Filoteo Alano, were named as co-defendants, although his name did not appear in the substantive allegations.

Motion to Dismiss in the First Case

• On November 16, 1987, private respondent Alano filed a motion to dismiss the complaint against him.
• His arguments included:
• The complaint failed to state a cause of action against him because it did not establish any contractual relation.
• The allegations did not mention his participation in the transactions underlying the promissory notes, letters of credit, or trust receipts.
• The complaint was procedurally defective as it did not include certain annexed documents (labeled “S,” “T,” and “U”) required by Section 7, Rule 8 of the Rules of Court.
• The petitioner opposed the motion to dismiss, but the RTC, on June 20, 1988, granted the dismissal on the ground that there was “no cause of action against defendant Alano.”

Procedural Developments Post-First Case

• After the RTC dismissed the complaint, the petitioner filed a motion for reconsideration, which the court denied on September 15, 1988, for lack of merit.
• An appeal was subsequently filed on September 30, 1988, and an appeal by certiorari was initiated with the Supreme Court (G.R. No. 86009) on December 14, 1988.
• The Supreme Court, in its Resolution on April 17, 1989, dismissed the petition on the grounds of late filing and lack of merit.

Initiation of the Second Case

• On October 31, 1990, the petitioner filed a new complaint with the RTC of Manila against private respondent Alano and another defendant, Feliciana Camara, being a surety from the first case.
• This second complaint (Civil Case No. 90-54998) restated the causes of action involving the same promissory notes, letters of credit, and trust receipts as in the first case.
• Alano again moved to dismiss the case, arguing:
• The issue against him had already been conclusively settled by the First Case (res judicata).
• The complaint still failed to state a cause of action against him.
• The RTC sustained Alano's motion to dismiss on March 1, 1991, and the Court of Appeals later affirmed the dismissal in its Decision on November 25, 1992.

Petition for Review

• Following the affirmation of the dismissal by the Court of Appeals, the petitioner elevated the issue by filing a petition for review on certiorari with the Supreme Court on January 21, 1993.
• The petitioner contended that:
• The dismissal in the First Case was not a judgment on the merits because it was merely based on a motion to dismiss.
• There was no identity of causes of action between the First and Second Cases since the Second Complaint included additional documents previously missing.
• The admission of allegations by the respondent in his motion to dismiss hypothetically evidenced his liability.

Core Contention

• The petitioner’s central argument was that the substantive differences between the two cases—particularly the inclusion of pertinent documents in the Second Case—should preclude the application of res judicata.
• Conversely, the respondent argued that all requisites for res judicata were fulfilled, thereby barring the relitigation of issues already adjudicated in the First Case.

Issue:

• Whether the Court of Appeals committed a reversible error in affirming the RTC’s dismissal of the Second Case on the ground of res judicata.
• Whether the dismissal of the First Case—even though effected through a motion to dismiss—constitutes a judgment on the merits.
• Whether there is absolute identity between the First Case and the Second Case in terms of parties, subject matter, and causes of action.
• Whether the petitioner’s claim that the addition of pertinent documents in the Second Case creates a distinct cause of action is legally tenable.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)