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    09 - Taar v. Lawan

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    Darby Joya
    The Supreme Court ruled that the private respondents were not barred by the principle of res judicata from filing free patent applications over the disputed property. For res judicata to apply, there must be identity of parties, subject matter, and causes of action between the first and second actions. While the Court of First Instance decision was a final judgment on the merits by a court of competent jurisdiction, there was no clear showing of substantial identity of parties or identity of subject matter between the CFI case involving a partition agreement and the current case determining occupancy rights over the property. Therefore, the requirements for invoking res judicata were not fully established.

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    09 - Taar v. Lawan

    Uploaded by

    Darby Joya
    390 views1 page
    The Supreme Court ruled that the private respondents were not barred by the principle of res judicata from filing free patent applications over the disputed property. For res judicata to apply, there must be identity of parties, subject matter, and causes of action between the first and second actions. While the Court of First Instance decision was a final judgment on the merits by a court of competent jurisdiction, there was no clear showing of substantial identity of parties or identity of subject matter between the CFI case involving a partition agreement and the current case determining occupancy rights over the property. Therefore, the requirements for invoking res judicata were not fully established.

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    The Supreme Court ruled that the private respondents were not barred by the principle of res judicata from filing free patent applications over the disputed property. For res judicata to apply, there must be identity of parties, subject matter, and causes of action between the first and second actions. While the Court of First Instance decision was a final judgment on the merits by a court of competent jurisdiction, there was no clear showing of substantial identity of parties or identity of subject matter between the CFI case involving a partition agreement and the current case determining occupancy rights over the property. Therefore, the requirements for invoking res judicata were not fully established.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    390 views1 page

    09 - Taar v. Lawan

    Uploaded by

    Darby Joya
    The Supreme Court ruled that the private respondents were not barred by the principle of res judicata from filing free patent applications over the disputed property. For res judicata to apply, there must be identity of parties, subject matter, and causes of action between the first and second actions. While the Court of First Instance decision was a final judgment on the merits by a court of competent jurisdiction, there was no clear showing of substantial identity of parties or identity of subject matter between the CFI case involving a partition agreement and the current case determining occupancy rights over the property. Therefore, the requirements for invoking res judicata were not fully established.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    RES JUDICATA

    Taar v. Lawan

    October 11, 2017 G.R. No. 190922 Leonen, J.

    Relevant Provisions/Concepts/Doctrines

    Doctrine of Res Judicata

    FACTS

    A parcel of land (property) was the subject for partitioning which was already decided by the CFI of Tarlac. The
    owners of the property are the predecessors-in-interest of herein petitioners. Petitioners were preparing a
    subdivision plan for the property, then applied for free patents over the property. However, private respondents
    protested their application on the ground that their predecessor-in-interest had been in an actual, physical,
    exclusive, and notorious possession and occupation of the land. Petitioners said that the private respondents
    occupied the property as tenants. The Director of DENR found out that the private respondents were the actual
    occupants of the property. Hence, the application for free patent was denied. Private respondents then filed a free
    patent application over the property and the Secretary of DENR reversed the decision of the Director, and denied
    their application as well. Thereafter, Office of the President (OP) opined that the Secretary of DENR erred in
    reversing the decision of the Director since the judgment was already final. The petitioners filed a petition before
    the CA alleging that the OP committed grave abuse of discretion in reinstating the DENR Director’s Order when in
    fact, the CFI already declared that the predecessors-in-interest were the ipso jure owners of the property.

    ISSUE

    Are the private respondents barred by the principle of res judicata from instituting free patent applications over the
    property claimed by the petitioners?

    RULING

    No. To invoke the application of res judicata, the following must be established:
    1. the judgment sought to bar the new action was 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
    4. there must be as between the 1st and 2nd action: identity of parties, subject matter, and causes of action

    In this case, the decision of CFI was a final judgment on merits rendered by a court of competent jurisdiction. The
    4th requirement, however, was not established for the petitioners to invoke the application of res judicata. In
    relation to identity parties, res judicata only requires substantial identity which means that the interest of the parties
    in the 1st case and 2nd case must be common. Moreover, there must also be an identity of subject matter. In the
    decision of CFI, the parties were the predecessors-in-interest and it was an agreement between them to partition
    the property. In the instant petition, it refers to the same property as that from CFI. However, there is no clear
    showing that the private respondents or the predecessors-in-interest have a common interest with any of the
    parties in the CFI’s decision. Also, the subject matter in the decision of CFI is merely an agreement to partition
    while in the instant petition, this involves the determination of who has the right to occupy the property

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