Facts:

• The case involves Carlos Llorana and Clarita Cataluna (petitioners) against Judge Tomas Leonidas and members of the Gener family (respondents).
• The dispute began on December 19, 1966, with the filing of Civil Case No. M-87 by Precila Gener and her family against their mother, siblings, and the Llorana Spouses.
• The claim sought recovery of possession, annulment of partition, accounting, and damages regarding two hectares of riceland in Tapaz, Capiz.
• The basis for the claim was an extra-judicial settlement from July 10, 1961, which adjudicated the property to Precila.
• The Llorana Spouses countered with a cross-claim, asserting that the Gener family sold them the land with a right of repurchase, which was not exercised in time.
• On April 25, 1968, the court ruled in favor of the Gener family, ordering the Llorana Spouses to return the riceland and pay damages.
• The Llorana Spouses' motion for reconsideration was denied, making the judgment final.
• They filed Civil Case No. M-159 on April 10, 1969, to enforce the warranty against eviction, which was dismissed for lack of prosecution on March 20, 1973.
• Civil Case No. M-260 was filed on November 19, 1972, seeking annulment of the M-87 judgment, but was dismissed as final.
• On May 4, 1973, the Llorana Spouses initiated Civil Case No. M-271 against the Gener family for enforcement of the warranty against eviction.
• The Gener family moved to dismiss M-271, claiming it was barred by the prior judgment in M-87.
• On July 10, 1974, the respondent Judge dismissed M-271, stating the judgment in M-87 was an absolute bar.
• The Llorana Spouses' motion for reconsideration was denied, leading to the current petition for certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in the affirmative, affirming the order of the respondent Judg...(Unlock)

Ratio:

• The Court outlined four requisites for the principle of res judicata to apply:
  1. A final former judgment must exist.
  2. The former judgment must be rendered by a court with jurisdiction over the subject matter and parties.
  3. The former judgment must be a judgment on the merits.
  4. There must be identity of parties, subject matter, and cause of action between the first and second actions.
• In this case:
  • The judgment in Civil Case No. M-87 was final and unappealed, satisfying the first requisite.
  • The Court of First Instance of Capiz had jurisdiction, meeting the second requisite.
  • The judgment in M-87 was...continue reading