Facts:

This case involves Amante O. San Pedro as the petitioner and Marciana M. Binalay, assisted by her husband Roberto Buluran and Wilson M. Binalay, as the respondents. The events relevant to the case transpired on May 22, 1985, when the petitioner filed a complaint for "Specific Performance with Damages" against the respondents in the Regional Trial Court at Tuguegarao, Cagayan, under Civil Case No. 3467. The petitioner alleged that on December 18, 1981, the respondents executed a deed of absolute sale in his favor concerning a parcel of land covering 219 square meters and identified as Transfer Certificate of Title (TCT) No. T-55830. It was claimed that the respondents failed to register the deed, prompting the petitioner to seek a declaration of ownership and registration of the deed in his name.

Respondents, however, denied executing the deed of sale, asserting that it was fictitious and contested its authenticity. Following a pre-trial, the petitioner requested to wit

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Facts:

Initial Filing and Allegations

• On May 22, 1985, petitioner Amante D. San Pedro filed a suit for "Specific Performance with Damages" in the Regional Trial Court at Tuguegarao, Cagayan (Civil Case No. 3467).
• Petitioner's complaint alleged that on December 18, 1981, the respondents executed a deed of absolute sale in his favor covering a parcel of land (219 square meters) with Transfer Certificate of Title (TCT) No. T-55830.
• The petitioner sought:
• A declaration of ownership over the subject property;
• The registration of the deed of sale; and
• The issuance of a certificate of title in his name.
• Respondents, in their verified Answer with counterclaim, denied the execution of any such deed. They alleged that they never sold the parcel and maintained that the deed was fictitious and a falsification.

Pre-Trial Developments and Withdrawal

• Before presenting evidence, petitioner filed a Motion to Withdraw Complaint, stating that he was no longer interested in prosecuting the case.
• In response, the respondents filed a Manifestation and Counter-Motion agreeing to the dismissal provided it was with prejudice.
• Both parties mutually agreed to dismiss the complaint and counterclaim with prejudice, resulting in an order dated August 27, 1990, dismissing the case (Civil Case No. 3467).

Second Filing and Res Judicata Allegation

• On February 11, 1992, petitioner filed a new suit for "Recovery of Possession and Ownership with Damages" in the same Regional Trial Court (Civil Case No. 4404) regarding the same land, now covered by TCT No. T-55380.
• Respondents moved to dismiss this action on the ground of res judicata, contending that the earlier dismissed case (Civil Case No. 3467) precluded any further litigation on the same subject matter and claims.
• The trial court granted respondents’ motion and dismissed Civil Case No. 4404 on September 16, 1992.

Appellate Proceedings and Subsequent Petition

• Dissatisfied with the dismissal, petitioner appealed the trial court’s decision to the Court of Appeals.
• The Court of Appeals, in its decision dated June 28, 1996, affirmed the dismissal on the basis that the voluntary dismissal in Civil Case No. 3467 barred subsequent litigation — essentially invoking the doctrine of res judicata.
• Petitioner later filed a motion for reconsideration, which was denied by the Court of Appeals on August 13, 1996.

Petitioner’s Arguments on Review

• Petitioner contended that:
• The causes of action in Civil Case No. 3467 (for specific performance) and Civil Case No. 4404 (for recovery of possession and ownership) were not identical; and
• Applying the res judicata principle in the latter case would result in an injustice.
• These arguments formed the basis of his petition for review on certiorari before the Supreme Court.

Issue:

• Whether the application of the doctrine of res judicata is proper in dismissing Civil Case No. 4404 given the prior voluntary dismissal in Civil Case No. 3467.
• Whether there is an identity of causes of action between the two cases despite the difference in the form of the pleadings (specific performance versus recovery of possession and ownership).
• Whether petitioner’s arguments that invoking res judicata would result in injustice can justify relaxing its well-established application, considering the essential facts and reliefs sought in both suits.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)