Case Summary (G.R. No. 165697)
Background of Cases
The proceedings are interconnected with earlier decisions of this Court, namely Valdehueza v. Republic (1966), which upheld the judgment of expropriation of the lot and concluded that the previous owners were entitled only to the fair market value, not the recovery of possession. Further, in Yu v. Republic (1986), the Court of Appeals annulled a sale of the expropriated lot to the respondents, ruling they did not purchase the land in good faith. This earlier judgment became final and executory, establishing critical background for the current proceedings.
Proceedings in Lower Courts
On October 1, 1992, the respondents initiated a complaint for the reversion of the expropriated property against the Republic of the Philippines. The respondent claimed that the government’s abandonment of public purpose regarding the property provided a new cause of action. However, the Republic contested this assertion, citing res judicata, lack of cause of action, and forum-shopping as grounds for dismissal.
Trial Court's Dismissal
On November 16, 1995, the Regional Trial Court dismissed the complaint, affirming that the principle of res judicata applied, thereby preventing the respondents from claiming any right to the property. The trial court maintained that the judgment in the previous cases barred the current action due to the established finality of judgments regarding the subject matter.
Appellate Court's Reversal
Upon appeal, the Court of Appeals found no merit in the application of res judicata, reversing the trial court's dismissal. They remanded the case for further proceedings, contending that it was necessary to fully determine the merits of the respondents’ claims to reacquire the property.
Issues on Review
The petition for review raised key issues: whether the trial court correctly dismissed the complaint based on res judicata, whether the abandonment of the Lahug Airport conferred a new cause of action, and whether respondents had any rightful claim to ownership.
Res Judicata Explained
The principle of res judicata holds that a final judgment by a competent court is conclusive on the parties involved. The elements require that the earlier judgment be final, rendered by a competent jurisdiction, a determination on merits, and identity of parties and subject matter between the cases. While the initial elements were satisfied, the core issue surrounded whether there was an identity of causes of action.
Legal Analysis of Causes of Action
The Court elaborated that res judicata has two aspects: "bar by prior judgment" and "conclusiveness of judgment." The distinction lies in whether there is complete identity of causes of action or merely identity of issues. In this context, while the sale to the respondents was invalidated in Yu v. Republic, they now sought to enforce rights founded on the nullified sale.
Doctrine of Conclusiveness of Judgment
The doctrine of conclusivene
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Case Background
- The case involves a review on certiorari of the Decision dated December 2, 2002, from the Court of Appeals in CA-G.R. CV No. 53712.
- The Court of Appeals set aside the dismissal by the Regional Trial Court of Cebu, Branch 11, regarding Civil Case No. CEB-12968.
- The appeal relates to the case's historical context involving previous decisions in Valdehueza v. Republic and Yu v. Republic.
Previous Case References
Valdehueza v. Republic (1966):
- The Supreme Court affirmed the judgment of expropriation of Lot No. 939 in Lahug, Cebu City.
- The ruling stated that the petitioners were entitled only to the fair market value of the lot, not to its possession.
Yu v. Republic (1986):
- The Court of Appeals annulled a subsequent sale of the lot by Valdehueza to the respondents, ruling that the respondents were not purchasers in good faith.
- This judgment became final and executory as the parties did not appeal.
Proceedings in Trial Court
- On October 1, 1992, the respondents filed a complaint for reversion of the expropriated property.
- The Republic of the Philippines denied the respondents' right to reacquire title, citing res judicata, lack of cause of action, and forum-shopping.
- The trial court dismissed the complaint on November 16, 1995, citing res judicata.
Court of Appeals Ruling
- The Court of Appeals ruled that there was no res judicata and remanded the case for further proceed