Urbana Velasco Aroc vs. People’s Homesite and Housing Corp.

Res Judicata – “a thing decided”; bar re-litigation of cases between the same parties in court

Facts:
1. Urbana Velasco Aroc (plaintiff-appellant) and family and Cirilio B. Garcia (defendant-
appellees) have each been living in ½ of the lot under contest.
2. Plaintiff filed with People’s Homesite and Housing Corporation (defendant-appellee) lot an
application for award of sale of the portion she is occupying.
3. Corporation however awarded the sale of the lot to defendant.
4. Plaintiff filed a case in the Court of First Instance in Rizal for annulment of award and deed of
sale, but this case was dismissed after a case for quieting of title and/or recovery of possession
involving the same lot was tried in Quezon City and the lot was awarded to the defendant.
5. Appeal by plaintiff to the Court of Appeals was dismissed based on the doctrine of res judicata.

Issue: W/N the Court of Appeals erred in dismissing the complaint of the plaintiff on the ground
of res judicata.

Held: Yes

Ratio:
1. In determining between the 2 cases, it must be examined if the requisites of res judicata are
present:
1) The former judgment must be final
2) it must have been rendered by a court having jurisdiction over the subject matter and
over the parties
3) it must be a judgment on the merits
4) there must be, between the first and second actions, identity of parties, of subject
matter and cause of action

2. It is only in the identity of cause of action (“cause of action” – an act or omission of second
party in violation of the legal right or rights of the other, and its essential elements are legal right
of the plaintiff, correlative obligation of the defendant, and act or omission of the defendant in
violation of said legal right) that the parties dispute and disagree.

First case seeks only to remove the cloud on the title of the land (make who
really owns the land clear) while second case seeks to nullify the award and sale of lot to
awardee. The second issues are more basic and fundamental vs. the issues in the first
case.

3. The test generally applied to res judicata is to consider the identity of facts essential to their
maintenance (whether the same evidence would sustain both cases). If the same facts would
sustain both = the two actions are considered the same and a judgment in the former is a bar to
the subsequent action of the latter. If the two actions (cases) rest upon different state of facts = a
judgment in one is no bar in the maintenance of the other.

In this case, the second case requires more evidence to be proven (thus requisite
#4 is not fulfilled). What’s more, PHHC was not impleaded as a party litigant in the first
case (again requisite #4 is not fulfilled)