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REPUBLIC v. RAMON YU

FACTS:

This case involves a dispute over the ownership of a piece of land. In a previous decision titled Yu v. Republic, the Court of Appeals annulled the subsequent sale of the lot by Francisca Valdehueza, et al., to the respondents, Ramon Yu, et al., and declared the respondents as not purchasers in good faith. The parties did not appeal this decision, and it became final and executory.

On October 1, 1992, the respondents filed a complaint for reversion of the expropriated property. The petitioner, the Republic of the Philippines, denied the respondents' right to reacquire the property on the grounds of res judicata, lack of cause of action, and forum-shopping. The trial court dismissed the complaint based on res judicata. However, on appeal, the Court of Appeals ruled that there was no res judicata and remanded the case to the trial court for further proceedings.

The petitioner argues that the trial court properly dismissed the complaint based on res judicata and asserts that the respondents have no right to assert ownership as their previous sale was invalidated in the previous case. The respondents counter that the action is not barred by res judicata as the abandonment of the government of the public purpose constitutes a new cause of action.

The doctrine of res judicata, which provides that a final judgment on the merits is conclusive as to the rights of the parties, is the main issue in this case. The petitioner argues that since the sale on which the respondents base their right to reversion has been nullified, they have no legal standing to bring forth the action for reversion of the expropriated property. The second issue of whether the abandonment of the Lahug Airport gives the respondents a new cause of action becomes moot and academic based on the determination of res judicata.

ISSUES:

  1. Whether the trial court properly dismissed the complaint on the ground of res judicata.

  2. Whether the abandonment of Lahug Airport and return of other expropriated properties gave respondents a new cause of action.

  3. Assuming a new cause of action, whether respondents have the right to assert ownership in the first place.

RULING:

  1. The Supreme Court ruled in favor of the petitioner and affirmed the decision of the trial court. The Court found that the action is barred by res judicata and that the respondents have no legal personality to assert ownership over the expropriated property.

PRINCIPLES:

  • Res judicata means a matter adjudged or a thing judicially acted upon or decided, and lays the rule that a final judgment rendered on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all other actions or suits in the same or any other judicial tribunal of concurrent jurisdiction on the points and matters in issue in the first suit.

  • The elements of res judicata are: (1) finality of the judgment; (2) rendered by a court having jurisdiction over the subject matter and parties; (3) disposition of the case being a judgment on the merits; and (4) identity of parties, subject matter, and causes of action between the first and second actions.

  • Res judicata can have two concepts: "bar by prior judgment" and "conclusiveness of judgment." "Bar by prior judgment" requires identity of parties, subject matter, and causes of action between the first and second cases, while "conclusiveness of judgment" only requires identity of parties and subject matter, but not identity of causes of action, and it applies when facts and issues actually and directly resolved in a former suit cannot be raised again in any future case between the same parties.

  • A final judgment on the merits rendered by a court of competent jurisdiction is conclusive as to the rights of the parties and their privies and constitutes an absolute bar to subsequent actions involving the same claim, demand, or cause of action.

  • Lack of legal personality to sue means that the party does not have the right to bring forth the action and is not the real party-in-interest. It is a ground for the dismissal of the case, along with the ground that the complaint does not state a cause of action.