PHILIPPINE FARMING CORPORATION, LTD vs. ALEJANDRO LLANOS, ET AL.

G.R. No. L-21014 (August 14, 1965)

J. Bengzon

This case highlighted that res judicata embraces two concepts: bar by prior judgment and conclusiveness of
judgment.

FACTS:

 Philippine Farming Corporation, Ltd. (Hawaii) executed on July 11, 1950, a deed of sale to transfer ownership
of land situated in Tinajeros, Malabon (then part of Rizal) covered by Transfer Certificate of Title No. 1584 to
Llanos, Et al for P30,000.00.
 Upon the completion of the sale, the buyers were subsequently issued by the Register of Deeds of Rizal
Transfer Certificate of Title No. 19248 covering said parcel of land.
 Philippine Farming Corporation, Ltd. (Philippines) then filed in August 1950 in the Court of First Instance of
Rizal a suit docketed as Civil Case No. 1209 to annul and declare the deed of sale as null and void as well as
to cancel TCT No. 19248 in the buyers' name and reinstate TCT 1584, allegedly in plaintiff's name.
 However, on September 29, 1950, Philippine Farming Corporation, Ltd. (Philippines), moved to dismiss its
complaint in Civil Case No. 1209 stating that a settlement has been made between them and Llanos, Et al,
who concurred to the said motion, making court dismiss the complaint.
 Philippine Farming Corporation, Ltd. (Philippines) later sought to withdraw its motion to dismiss and to annul
the order of dismissal, alleging deceit on the part of the defendants. Still later, however, it moved that its
motion for withdrawal be itself considered withdrawn, and the court granted said last motion on November
20, 1950.
 Sometime in 1960, Philippine Farming Corporation, Ltd. (Philippines) filed the present suit in the Court of
First Instance of Rizal, docketed therein as Civil Case No. 6322, which has the same issue and defendants
with the first case files (Civil Case No. 1209) which was decided upon with finality by the court.
ISSUE:

Whether or not Philippine Farming Corporation, Ltd. (Philippines) can file Civil Case No. 6322 with the same
issue and defendants with Civil Case No. 1209 even though the court has already rendered its judgment on the latter.

RULING:

NO. The Supreme Court stated that the dismissal in said Civil Case No. 1209 was by a final order since
thereafter nothing was left to be disposed of. Similarly, the cause of action is identical. As stated in Peñalosa v.
Tuazon, 22 Phil. 303, the test is: "Would the same evidence support and establish both the present and former causes
of action?" In the instant case, the same evidence, namely, plaintiff's ownership of the parcel of land and that the
sale thereof was contested, would support and establish the present and former causes of action. It is therefore
identical. Thus, the court dismissed the complaint on the ground of res judicata. The requisites for res judicata are:
(1) court of competent jurisdiction; (2) final judgment or order on the merits; and (3) identities of parties, subject
matter, and cause of action (San Diego v. Calderon, 70 Phil. 281, 283).