Case Digest (A.M. No. R-146-P) Core Legal Reasoning Model
Facts:
This case involves Teresita S. Lee as the petitioner and Lui Man Chong as the respondent. It originated from a series of legal disputes following the intestate death of Conrado P. Romero on January 17, 2006. Romero left behind four parcels of land in Baguio City and 4,600 shares of Pines Commercial Corporation (PCC). Chong, claiming to be Romero's nephew, executed an Affidavit of Self-Adjudication on February 23, 2006, declaring himself as the sole heir and subsequently transferring the titles of the properties to his name.
Lee, asserting that she was Romero's common-law wife, filed a Petition for Letters of Administration on April 10, 2006, which was dismissed by the Regional Trial Court (RTC) of Baguio City, Branch 5 (RTC Br. 5), in Special Proceedings Case No. 1646-R, on August 24, 2006. This dismissal was later affirmed by the Supreme Court. Following this, Lee, along with Linda Ng-Perido, initiated a complaint for the Declaration of Nullity of the Affidavit of Sel
Case Digest (A.M. No. R-146-P) Expanded Legal Reasoning Model
Facts:
- Death of Conrado P. Romero and Claim of Heirship
- On January 17, 2006, Conrado P. Romero died intestate, leaving behind properties, including four parcels of land in Baguio City and 4,600 shares of Pines Commercial Corporation (PCC).
- On February 23, 2006, respondent Lui Man Chong, claiming to be Romero’s nephew, executed an Affidavit of Self-Adjudication, declaring himself the sole heir and transferring the titles of the properties to his name.
- Petitioner’s Claim as Common-Law Wife
- On April 10, 2006, petitioner Teresita S. Lee, claiming to be Romero’s common-law wife, filed a Petition for Letters of Administration before the Regional Trial Court (RTC) Branch 5, docketed as Special Proceedings Case (SPC) No. 1646-R.
- The RTC Branch 5 dismissed the petition on August 24, 2006, and the dismissal was affirmed by the Supreme Court.
- Annulment Case
- On August 24, 2006, Lee, along with Linda Ng-Perido, filed a complaint for Declaration of Nullity of Affidavit of Self-Adjudication against Chong before RTC Branch 61, docketed as Civil Case No. 6328-R.
- Lee claimed to be a co-owner of Romero’s properties, alleging that she and Romero cohabited and jointly acquired the properties.
- On April 29, 2008, RTC Branch 61 dismissed the case for lack of cause of action and legal personality, as Lee failed to prove her status as a common-law spouse. This dismissal was affirmed and became final on January 12, 2009.
- Recovery Case
- On September 4, 2008, Lee filed another case for Annulment of Title with Damages, later amended to Recovery of Ownership, before RTC Branch 60, docketed as Civil Case No. 6761-R.
- Lee reiterated her claim of co-ownership over the properties, alleging that she and Romero jointly acquired them during their cohabitation.
- Chong moved to dismiss the case, arguing lack of jurisdiction, lack of cause of action, and res judicata, citing the finality of the Annulment Case.
- On August 8, 2011, RTC Branch 60 granted Chong’s motion to dismiss on the ground of res judicata, stating that the issues in the Recovery Case had already been settled in the Annulment Case.
- Appeal to the Court of Appeals
- Lee appealed to the Court of Appeals (CA), which affirmed the RTC’s dismissal on May 24, 2013, holding that the doctrine of res judicata (bar by prior judgment) applied.
- The CA noted that the Annulment Case and the Recovery Case involved the same parties, subject matter, and causes of action, and that the dismissal of the Annulment Case was a final adjudication on the merits.
- Lee’s motion for reconsideration was denied by the CA on October 7, 2013.
- Petition to the Supreme Court
- Lee filed a petition for review on certiorari before the Supreme Court, arguing that the CA erred in applying res judicata and that its application would sacrifice justice to technicality.
Issues:
The primary issue is whether the Court of Appeals erred in affirming the dismissal of the Recovery Case on the ground of res judicata, specifically whether the doctrine of bar by prior judgment applies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied Lee’s petition, upholding the dismissal of the Recovery Case on the ground of res judicata. The Court ruled that the Annulment Case and the Recovery Case involved the same parties, subject matter, and causes of action, and the prior judgment in the Annulment Case barred the subsequent Recovery Case.