G.R. No. L-27388 - Rasay-Lahoz vs. Leonor

Plaintiffs – Trinidad Rasay-Lahoz, Remedios Rasay-Nepomuceno, Iluminada Rasay-Jocson, Josefina Rasay-Mauck, Edelwina Rasay, and Cenon Rasay – initiated a complaint against defendants Domingo Leonor, Juliana R. de Leonor, and Francisco Leonor.
The complaint was originally instituted on July 2, 1965, in Civil Case No. 4731 of the Court of First Instance of Davao.
The relief sought by plaintiffs was multifold:

A declaration that two deeds of sale were “fraudulent and fictitious” (later changed to “fictitious and simulated and void ab initio”) and therefore null and void.
An order directing Francisco Leonor to reconvey and deliver to the plaintiffs the parcels of land described in these deeds of sale.
An accounting of the fruits of the said land, and payment for damages, attorney’s fees, and costs.

The first deed was executed by Juliana R. de Leonor on May 10, 1956, in favor of Elena R. Ledesma.
The second deed was executed by Elena R. Ledesma on May 18, 1956, in favor of Francisco Leonor.
Both deeds were contested on the basis that they were fraudulent and fictitious, implying that the conveyance of title was vitiated by fraud.

In Case No. 4731, defendants moved to dismiss the complaint before the merits could be considered, invoking both the statute of limitations of action and the doctrine of laches.
The Court of First Instance of Davao granted the motion to dismiss on October 23, 1965, ruling that the complaint was barred by prescription.
Not long after, on November 5, 1965, plaintiffs filed a new action – Civil Case No. 4856 – in the same court against the same defendants, with a complaint essentially identical in substance to that in Case No. 4731, albeit with minor verbal changes.

Both complaints involved identical parties and addressed the same set of fabricated or fraudulent deeds of sale.
The alleged wrong committed by the defendants in both suits centered on the deceptive conveyance of land title, resulting in the deprivation of the plaintiffs’ rights as heirs.
The relief that plaintiffs would have obtained if the allegations were proven in either case would have been substantially the same, whether by declaring the deeds null and void or void ab initio.

The dismissal order in Case No. 4731 was rendered neither as “without prejudice” nor on the ground of lack of jurisdiction, thereby operating as a dismissal on the merits.
As a result, the dismissal became final and executory, effectively barring any subsequent action based on the same cause of action.

Whether the present action (Civil Case No. 4856) is barred by the order of dismissal in Case No. 4731.
Whether the slight change in the phrasing of the prayer for relief (from “null and void and without any effect whatsoever” to “void ab initio”) circumvents the principle of res judicata.

Whether the plaintiffs’ failure to amend the original complaint in Case No. 4731 negates their opportunity to address any alleged deficiencies, thus validating the dismissal on the merits.
How the doctrine of res judicata applies when both actions involve identical parties, subject matter, and cause of action.