Case Digest (G.R. No. 75377)
Facts:
Chua Keng Giap v. Hon. Intermediate Appellate Court and Chua Lian King, G.R. No. 75377, February 17, 1988, First Division, Cruz, J., writing for the Court.Petitioner Chua Keng Giap filed on May 19, 1983 a petition for the settlement of the estate of the late Sy Kao in the Regional Trial Court (RTC) of Quezon City. Chua Lian King (private respondent) moved to dismiss the petition on the ground that petitioner lacked a cause of action and the capacity to sue, relying on the adjudication in Special Proceeding No. Q-12592 (the settlement of the estate of the late Chua Bing Guan) which had declared petitioner not to be the son of the spouses Chua Bing Guan and Sy Kao.
Judge Jose P. Castro of the RTC denied the motion to dismiss, reasoning that the earlier proceeding had decided paternity and not maternity and thus did not conclusively dispose of petitioner’s asserted filiation to Sy Kao. The private respondent filed a petition for certiorari with the Intermediate Appellate Court (the respondent court), which reversed the trial judge—its decision was penned by Kapunan, J., concurred in by Sison, Lazaro and Cruz, JJ. The motion for reconsideration to the Intermediate Appellate Court was denied as tardy.
Petitioner then sought relief from the Supreme Court to challenge the Intermediate Appellate Court’s reversal of the RTC order and the denial of reconsideration. The Supreme Court noted that the question of petitioner’s filiation had been previously adjudicated and finally resolved in earlier proceedings, including the Supreme Court’s own decision in Sy Kao v. Court of Appeals, 132 SCRA 302, which had expressly found that Sy Kao denied maternity and that petitioner had no lawful interest in the related estate. The prior litigation history included a ten‑year hearing in Special Proceeding No. Q-12592, dismissal of...(Pro-only)
Issues:
- Is petitioner’s present claim of filiation and capacity to sue in the estate settlement barred by prior final judgments (res judicata)?
- Was the denial of the motion for reconsideration by the Intermediate Appellate Court erroneous as untimely in view of the Habalu...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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