MONICO LIGTAS v.

PEOPLE OF THE PHILIPPINES

SECOND DIVISION; G.R. No. 200751, August 17, 2015

LEONEN, J.:

Doctrine:
Res judicata applies also in administrative cases- the rule which forbids the reopening of a matter
once judicially determined by competent authority applies as well to the judicial and quasi-judicial
facts of public, executive or administrative officers and boards acting within their jurisdiction as
to the judgments of courts having general judicial powers.

Facts:

Ligtas was charged with the crime of theft under Article 308 of the Revised Penal Code for
unlawfully and feloniously harvesting 1,000 kilos of abaca fibers, valued at Php29,000.00 at
Php29.00 per kilo, without the consent of said owner, Anecita Pacate. The DARAB rendered the
Decision ruling that Ligtas was a bona fide tenant of the land.While records are bereft as to when
the DARAB Decision was formally offered as evidence before the trial court, records are clear that
the DARAB Decision was considered by both the trial court and Court of Appeals and without any
objection on the part of the People of the Philippines. The Regional Trial Court held that the
prosecution was able to prove the elements of theft and held Ligtas guilty thereof. On appeal, the
Court of Appeals affirmed the trial Court. The Court of Appeals declared that Ligtas' reliance on
the DARAB Decision declaring him as a bonafide tenant of the land is irrelevant in the case at bar.
Hence, this case.

Issue:

Whether or not DARAB Decision, finding petitioner Monico Ligtas as tenant of the land owned
by private complainant is conclusive or can be taken judicial notice of in a criminal case for theft

Ruling:

Yes. The Supreme Court ruled that in this case, the findings of the DARAB were supported by
substantial evidence. Generally, decisions in administrative cases are not binding on criminal
proceedings. However, this case does not involve an administrative charge stemming from the
same set of facts involved in a criminal proceeding. Significantly, respondent did not appeal the
Decision of the DARAB; consequently, the same has attained finality and constitutes res
judicata on the issue of petitioner's status as a tenant of respondent.

Res judicata is a concept applied in the review of lower court decisions in accordance with the
hierarchy of courts. But jurisprudence has also recognized the rule of administrative res judicata:
The rule which forbids the reopening of a matter once judicially determined by competent
authority applies as well to the judicial and quasi-judicial facts of public, executive or
administrative officers and boards acting within their jurisdiction as to the judgments of courts
having general judicial powers. Res judicata embraces two concepts: (1) bar by prior judgment as
enunciated in Rule 39, Section 47(b) of the Rules of Civil Procedure; and (2) conclusiveness of
judgment in Rule 39, Section 47(c).There is "bar by prior judgment" when, as between the first
case where the judgment was rendered and the second case that is sought to be barred, there is
identity of parties, subject matter, and causes of action. In this instance, the judgment in the first
case constitutes an absolute bar to the second action. But where there is identity of parties in the
first and second cases, but no identity of causes of action, the first judgment is conclusive only as
to those matters actually and directly controverted and determined and not as to matters merely
involved therein. This is the concept of res judicata known as "conclusiveness of judgment." Stated
differently, any right, fact or matter in issue directly adjudicated or necessarily involved in the
determination of an action before a competent court in which judgment is rendered on the merits
is conclusively settled by the judgment therein and cannot again be litigated between the parties
and their privies, whether or not the claim, demand, purpose, or subject matter of the two actions
is the same.

The elements of res judicata are: (1) the judgment sought to bar the new action must be final; (2)
the decision must have been rendered by a court having jurisdiction over the subject matter and
the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be
as between the first and second action, identity of parties, subject matter, and causes of
action. Should identity of parties, subject matter, and causes of action be shown in the two cases,
then res judicata in its aspect as a "bar by prior judgment" would apply. If as between the two
cases, only identity of parties can be shown, but not identical causes of action, then res judicata as
"conclusiveness of judgment" applies. In the DARAB, there being no appeal interposed therefrom,
attained finality. Accordingly, the matter regarding the status of Ligtas as a tenant farmer and the
validity of the CLT and Emancipation Patents issued in his favor are settled and no longer open to
doubt and controversy.

The Supreme Court granted the petition.