G.R. No. 115829 - Nasser vs. Court of Appeals

Lourdes S. Flores, the natural mother of Angelito Maglalang (born July 6, 1966), initially filed a complaint for support on March 13, 1981, in the Court of First Instance of San Pablo City against Gil C. Maglalang.
Her complaint alleged that while employed as a domestic helper by Gil, they engaged in sexual relations resulting in the birth of Angelito; additionally, the birth was not properly recorded due to inadvertence.

Lourdes claimed that post-birth, for a period of four years, she was provided only a minimal weekly allowance of P10.00 for the child’s expenses.
She further stated that for her own maintenance, she received P15.00 a month until the child's elementary graduation, which later increased to P20.00 until September 1980.
Lourdes also detailed the hardships she endured thereafter, including working conditions that led to illness, and her subsequent need for a monthly allowance of P500.00 for the support and education of the child, along with an additional P200.00 monthly for support pendente lite and attorney’s fees.

The parties jointly filed a motion to dismiss the initial complaint, making three key assertions:

Lourdes expressed serious doubts regarding whether Gil was the biological father of Angelito.
Based on her doubts, she argued that Article 283 of the Civil Code was inapplicable, and she was no longer interested in pursuing the case.
Both parties waived any further claims and counterclaims against each other.

The Regional Trial Court of San Pablo City granted this joint motion, dismissing the case with prejudice on August 11, 1983.

On February 11, 1987, Lourdes filed a motion for leave of court to revive the support case on behalf of her now-major son, Angelito Maglalang; this motion was denied on March 23, 1987, along with two subsequent motions for reconsideration.
Angelito, seeking acknowledgment of his status as the natural child of Gil and support, then filed a new complaint on April 29, 1987, in the same court.
Gil responded with a motion to dismiss the complaint on the grounds of res judicata and lack of cause of action.
The trial court dismissed Angelito’s complaint on June 2, 1987, a decision later affirmed by the Court of Appeals on June 20, 1988, with a subsequent motion for reconsideration by Angelito being denied on August 5, 1988.

The case also involved a secondary issue regarding whether a case that involves the civil status of a person (in this instance, the acknowledgment of a natural child) should first be submitted to barangay arbitration in accordance with Section 6 of Presidential Decree No. 1508.
It was emphasized that such matters are encouraged to undergo a settlement process at the barangay level unless exceptions, such as cases involving detention, habeas corpus, or provisional remedies, apply.

Whether the principle of res judicata applies to bar Angelito Maglalang’s subsequent suit for support and acknowledgment as a natural child against Gil, given that a previous case involving the same parties, subject matter, and cause of action had already been dismissed with prejudice.

Whether a case involving the civil status of a person—specifically, the acknowledgment of a natural child—must first undergo barangay arbitration pursuant to Section 6 of Presidential Decree No. 1508 before being elevated to the courts.