Title
Fenix International, Inc. vs. Executive Secretary
Case
G.R. No. 235258
Decision Date
Aug 6, 2018
The case of Fenix (CEZA) International, Inc. v. Executive Secretary revolves around the dismissal of a Contempt Case by the Court of Appeals (CA) based on the grounds of res judicata and forum shopping, with the Supreme Court ruling in favor of Fenix and remanding the case for further proceedings.
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Case Digest (G.R. No. 235258)

Facts:

  • On December 12, 2002, President Gloria Macapagal-Arroyo issued Executive Order No. 156, banning the importation of used motor vehicles, except those allowed under its provisions.
  • The constitutionality of this order was questioned in a previous case.
  • On April 4, 2005, President Arroyo issued Executive Order No. 418, imposing a specific duty on imported used motor vehicles.
  • Fenix (CEZA) International, Inc., a domestic corporation engaged in the conversion and maintenance of imported used motor vehicles, filed a petition for declaratory relief against the Executive Secretary and other respondents, seeking the nullity of the executive orders.
  • The Regional Trial Court (RTC) ruled in favor of Fenix, and the decision became final and executory.
  • Another case questioning the validity of the ban on importations of used motor vehicles was filed by another party.
  • The Court ruled against the injunctive relief sought in that case, stating that the previous ruling in the Fenix Case did not reverse the ban on importations of used motor vehicles.
  • Fenix filed a petition for indirect contempt against the respondents, alleging that they were violating the previous ruling in the Fenix Case.
  • The RTC dismissed the petition on the grounds of res judicata and forum shopping.
  • Fenix appealed to the Court of Appeals (CA), but the CA affirmed the RTC's ruling.

Issue:

  • (Unlock)

Ruling:

  • The Court ruled in favor of Fenix, stating that res judicata did not apply in this case.
  • The Court als...(Unlock)

Ratio:

  • Res judicata refers to a matter that has been adjudged or settled by judgment.
  • There are two concepts of res judicata: bar by former judgment and conclusiveness of judgment.
  • Bar by former judgment applies when there is identity of parties, subject matter, and causes of action between the first and second cases.
  • Conclusiveness of judgment applies when there is identity of parties and subject matter between the first and second cases.
  • In this case, the Court found that the Fenix Case and the Cont...continue reading

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