Case Summary (G.R. No. 262092)
Facts of the Case
Conrado P. Romero died on January 17, 2006. Following his death, Lui Man Chong executed an Affidavit of Self-Adjudication on February 23, 2006, claiming exclusive heirship over Romero’s estate. Teresita S. Lee, claiming to be Romero’s common-law wife, filed a Petition for Letters of Administration, which was dismissed on August 24, 2006, along with a subsequent Annulment Case she filed against Chong to nullify the Affidavit. The Annulment Case was dismissed for lack of cause and legal personality, stating Lee had no right to Romero’s estate under the Civil Code, as she was not legally recognized as his spouse.
Legal Proceedings
Lee then filed a case on September 4, 2008, for Annulment of Title with Damages and subsequently amended it to a Recovery of Ownership, asserting entitlement to half of the properties based on their alleged cohabitation and shared business investments. Chong moved to dismiss the case, citing lack of jurisdiction, lack of cause of action, and res judicata, referencing the final judgment from the previous cases.
Trial Court's Ruling
The Regional Trial Court (RTC) of Baguio City, on August 8, 2011, dismissed the Recovery Case, stating that the previously adjudicated issues in the Annulment Case must remain settled. It noted that determining Lee's claim of co-ownership would necessitate revisiting the already resolved validity of Chong’s affidavit, which had been upheld by final judgment.
Court of Appeals' Decision
Lee appealed to the Court of Appeals (CA), which affirmed the RTC’s decision on May 24, 2013, citing the doctrine of res judicata and concluding that the Annulment Case’s dismissal constituted a bar against the current claims. The CA asserted that both cases involved identical parties, subject matter, and legally related causes of action, resulting in a judgment that had been conclusively settled.
Current Supreme Court Ruling
Lee's petition for review on certiorari was denied by the Supreme Court, which confirmed the application of res judicata, emphasizing the existence of a
...continue readingCase Syllabus (G.R. No. 262092)
Case Overview
- This case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
- The petitioner, Teresita S. Lee, is contesting the Decision dated May 24, 2013, and the Resolution dated October 7, 2013, of the Court of Appeals (CA) in CA-G.R. CV No. 98141.
- The CA's decision affirmed the dismissal of Lee's case for recovery of properties by the Regional Trial Court (RTC) of Baguio City, Branch 60, in Civil Case No. 6761-R.
Factual Background
- Conrado P. Romero died intestate on January 17, 2006, leaving behind four parcels of land in Baguio City and 4,600 shares of Pines Commercial Corporation (PCC).
- Respondent Lui Man Chong executed an Affidavit of Self-Adjudication claiming to be Romero's nephew and transferred the properties to his name.
- Teresita S. Lee alleged that she was Romero's common-law wife and filed a Petition for Letters of Administration on April 10, 2006, which was dismissed by the RTC.
- Lee subsequently filed a complaint for Declaration of Nullity of Chong's Affidavit of Self-Adjudication, which was also dismissed for lack of cause of action