G.R. No. 186366 - Heirs of Ferdo vs. De Belen

Remegio A. Ching was one of the original incorporators, members, trustee, and treasurer of San Pedro College of Business Administration (SPCBA), a domestic non-stock and non-profit corporation formerly known as Laguna College of Business Administration.
On September 19, 2001, Remegio tendered his irrevocable resignation, stating that his resignation applied to his positions as trustee and treasurer—not necessarily his membership.
Following his resignation, Remegio was paid P20,000,000.00, representing the buy-out price for his interest in SPCBA, although there was no conclusive evidence that the buyout equated to the termination of his membership.

On June 10, 2010, Remegio filed an intra-corporate case (SEC Case No. 86-2010-C) seeking the inspection of SPCBA’s books and documents, basing his claim on his status as a member.
Remegio argued that his resignation letter only covered his trustee and treasurer roles and did not affect his membership, thereby entitling him to inspect the corporate records.
The Regional Trial Court (RTC) granted his right to inspect, finding that:

There was no sufficient evidence that Remegio’s membership had ceased in the manner prescribed by SPCBA’s articles of incorporation or by-laws.
The buy-out payment did not conclusively establish that Remegio relinquished his status as a member.

SPCBA, disagreeing with the RTC’s favorable ruling toward Remegio, appealed the decision. However, it filed its appeal via a notice of appeal (docketed as CA-G.R CV No. 96608) instead of the proper petition for review, resulting in the dismissal of its appeal by the Court of Appeals (CA).
SPCBA subsequently pursued judicial remedies by filing a petition in the Supreme Court (docketed as G.R. No. 198807), which was denied for failure to show reversible error.
On February 16, 2012, SPCBA’s Board of Trustees adopted a resolution affirming Remegio’s removal not only from the posts of trustee and treasurer but also as a member of the corporation.
On April 4, 2012, the RTC’s decision in SEC Case No. 86-2010-C became final and executory following the entry of judgment.

On April 26, 2012, SPCBA filed a complaint (RTC-SEC Case No. 92-2012-C) against Remegio, seeking:

A judicial declaration validating his removal as trustee, treasurer, and member pursuant to the February 16, 2012 Board Resolution.
An injunction restraining him from filing nuisance or harassment suits against SPCBA.

Remegio countered by invoking the doctrine of res judicata, arguing that his membership issue had been already conclusively settled in SEC Case No. 86-2010-C.
The RTC, in its December 11, 2012 Omnibus Order, granted his res judicata defense by:

Holding that the issue of his membership had been decisively determined in the earlier case.
Striking off the relief seeking his removal as a member from the complaint.

The CA, however, reversed the RTC decision in its January 27, 2014 ruling by holding that:

The causes of action in the two cases were distinct because SPCBA’s subsequent Board Resolution introduced a “new fact” or supervening event.
The new cause of action under Section 91 of the Corporation Code, which pertained to termination of membership, was proper despite the earlier litigation.

Remegio then moved for reconsideration before the CA, which was denied, prompting the filing of the present petition for review with the Supreme Court.

Whether the Court of Appeals erred in rejecting Remegio’s assertion that the principle of res judicata barred the relitigation of his membership in SPCBA, which had already been determined in SEC Case No. 86-2010-C.
Whether the issuance of the February 16, 2012 Board Resolution by SPCBA constituted a supervening event or new cause of action sufficient to overcome the res judicata effect of the earlier case.
Whether the fundamental requirements for res judicata—final judgment on the merits, identical parties, and the sameness of issues—were met in SEC Case No. 86-2010-C such that it precluded SPCBA from relitigating Remegio’s membership status.
Whether SPCBA’s conduct, including the filing of appeals through erroneous modes and subsequent actions, amounted to forum shopping or an attempt to circumvent the conclusiveness of the prior judgment.