RES JUDICATA

The guiding principle of the doctrine of res judicata was formulated by Vice Chancellor Wigram in an English case circa 1843, thus:

xxx that where a given matter becomes the subject of litigation in, and of adjudication by, a court of competent jurisdiction, the court requires the parties to that litigation to bring forward their whole case, and will not (except under special circumstances) permit the same parties to open the same subject of litigation in respect of matter which might have been brought forward as part of the subject in contest, but which was not brought forward, only because they have, from negligence, inadvertence, or even accident, omitted part of their case. The plea of res judicata applies, except in special cases, not only to points which the court was actually required by the parties to form an opinion and pronounce a judgment, but to every point which properly belonged to the subject of litigation, and which the parties, exercising reasonable diligence, might have brought forward at the time. (Henderson v. Henderson, 3 Hare 100, pp. 114-115).

The doctrine is also known as estoppel per rem judicatam and involves both cause of action estoppel and issue estoppel. The purpose of the doctrine is two-fold - to prevent unnecessary proceedings involving expenses to the parties and wastage of the court's time which could be used by others, and to avoid stale litigations as well as to enable the defendant to know the extent of the claims being made arising out of the same single incident. (S. Sime, A Practical Approach To Civil Procedure, (1994 Ed.), Blackstone Press Ltd., London, p. 391).

Under the doctrine of res judicata, therefore, a final judgment or decree on the merits rendered by a court of competent jurisdiction is conclusive of the rights of the parties or their privies in all later suits and on all points and matters determined in the previous suit. (Dela Cruz v. Joaquin, G.R. No. 162788, July 28, 2005, 464 SCRA 576).

For res judicata to bar the institution of a subsequent action, the following requisites must concur: (a) the former judgment must be final; (b) it must have been rendered by a court having jurisdiction of the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be between the first and second actions identity of parties, identity of the subject matter, and identity of cause of action. (Custodio v. Corrado, G.R. No. 146082, July 30, 2004, 435 SCRA 500).

The foundation principle upon which the doctrine rests is that the parties ought not to be permitted to litigate the same issue more than once; that when a right or fact has been judicially tried and determined by a court of competent jurisdiction, so long as it remains unreversed, should be conclusive upon the parties and those in privity with them in law or estate.  (Republic v. Court of Appeals, G.R. No. 101115, August 22, 2002, 387 SCRA 549 cited in CATALINA BALAIS-MABANAG, assisted by her husband, ELEUTERIO MABANAG, vs. THE REGISTER OF DEEDS OF QUEZON CITY, CONCEPCION D. ALCARAZ, and RAMONA PATRICIA ALCARAZ, G.R. No. 153142 : March 29, 2010, BERSAMIN, J.).