Case Summary (G.R. No. 141528)
Procedural History and Disputed Legal Issue
On October 24, 1995, petitioner filed Civil Case No. SP 4341-95 seeking annulment on psychological incapacity grounds. The RTC denied this petition on November 11, 1997, for lack of sufficient evidence. The Court of Appeals dismissed his appeal for failure to pay docket fees. Subsequently, on July 12, 1999, petitioner filed a new petition for nullity based on the absence of a marriage license. Respondent moved to dismiss the second petition citing res judicata and forum shopping, which the RTC granted. Petitioner contests the dismissal, arguing that the two petitions involve different causes of action because they rely on different operative facts and evidence.
Doctrine of Res Judicata Defined and Policy Rationale
Res judicata, or "a matter adjudged," is the principle that a final judgment on the merits by a competent court conclusively settles the rights of parties in subsequent litigation on the same matter. It is rooted in public policy to prevent endless litigation and protect the stability of final judgments, thus preserving public peace and minimizing harassment of parties by repetitive lawsuits. Rule 39, Section 47 of the Rules of Court (“Effect of judgments or final orders”) codifies res judicata, emphasizing finality and conclusiveness in judgments to avoid multiplicity of suits.
Legal Standards Under Rule 39, Section 47
The provision entails a dual aspect: Section 47(b) relates to “bar by prior judgment,” preventing a subsequent suit on the same cause of action, while Section 47(c) deals with “conclusiveness of judgment,” barring re-litigation of matters necessarily included in a prior judgment even if framed under a different cause of action. Res judicata requires these elements: (1) final judgment on the merits, (2) court with jurisdiction over subject and parties, (3) identity of parties, and (4) identity of causes of action.
Analysis of Identity of Causes of Action
The sole issue disputed is whether there is identity of cause of action in the two petitions. The test to determine identity is whether the same evidence will sustain both actions or whether the essential facts are identical. Petitioner claims the causes are distinct since the first was based on psychological incapacity and the second on absence of marriage license, requiring different evidence.
Court’s Reasoning on Cause of Action and Evidence
The Court holds that petitioner merely invoked different grounds to attack the same cause of action: the nullity of the marriage. By definition, a cause of action is the act or omission violating a party’s legal right. Both petitions seek declaration of nullity of the same marriage, differing only in legal grounds. Thus, the grounds are aspects of the same pivotal issue — the marriage’s validity. Furthermore, in the first case, petitioner tacitly admitted the marriage was validly celebrated, now binding him against claiming later it was void due to license absence. The alleged lack of license could have been raised in the first case, and parties are bound by all matters that might have been raised to support or defeat claims.
Prohibition Against Splitting Causes of Action and Forum Shopping
The petitioner’s attempt to split the grounds for annulment into separate suits violates the rule against splitting causes of action and constitutes forum shopping. The Court emphasized a party must present all known grounds for relief in one action to avoid piecemeal litigation, which is discouraged to ensure finality an
...continue readingCase Syllabus (G.R. No. 141528)
Nature of the Case and Legal Issue Presented
- Petition for review on certiorari under Rule 45 of the Rules of Court.
- Core question: Whether a final judgment denying a petition for declaration of nullity of marriage due to psychological incapacity bars a subsequent petition on the ground of lack of a marriage license.
- Legal contention centers on res judicata, forum shopping, splitting of cause of action, and related procedural doctrines under Philippine law.
Factual Background
- Petitioner Oscar P. Mallion initially filed a petition on October 24, 1995, for declaration of nullity of his marriage to Editha Alcantara based on psychological incapacity under Article 36 of Executive Order No. 209, the Family Code.
- The Regional Trial Court (RTC) Branch 29, San Pablo City, hearing Civil Case No. SP 4341-95, denied this petition after trial on November 11, 1997, because petitioner failed to prove psychological incapacity.
- The Court of Appeals dismissed petitioner’s appeal on June 11, 1998, due to failure to pay required fees.
- After finality of this decision, petitioner filed a second petition on July 12, 1999, alleging that the marriage was null due to absence of a valid marriage license.
- Respondent moved to dismiss the second petition on grounds of res judicata and forum shopping; the RTC granted the motion on October 8, 1999.
- Petitioner’s motion for reconsideration was denied on January 21, 2000.
- Petitioner contested the dismissal, arguing that the prior judgment did not bar the subsequent petition as the causes of action differed.
Procedural Posture and Petitioner's Arguments
- Petitioner claims:
- Although both petitions sought the declaration of nullity of marriage, the causes of action were distinct due to different grounds.
- Psychological incapacity and lack of marriage license involve different operative facts and evidence.
- Therefore, res judicata should not bar the second action as there was no identity of causes.
- No forum shopping or splitting of cause of action occurred, since these were separate claims.
- Petitioner argues that the trial court wrongly applied res judicata and forum shopping doctrines by dismissing the second petition.
Respondent’s Counterarguments
- Respondent contends:
- Both petitions essentially address the same issue—the validity of the marriage.
- Both seek the same relief—the declaration of nullity of marriage.
- The second petition constitutes forum shopping.
- The ground alleged in the second petition could have been raised during the first proceeding.
- The rule on multiplicity of suits was violated.
Issue for Resolution by the Supreme Court
- Whether the previous final judgment denying nullity of marriage based on psychological incapacity bars a subsequent petition for nullity based on absence of marriage license.
- Specifically, whether the doctrines of res judicata, forum shopping, and splitting of cause of action apply in this context.
- Whether different grounds for nullity constitute separate ca