Res judicata vs. Conclusiveness of judgment

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Res judicata literally means "a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment."72 It rises from the underlying idea that parties should not to be permitted to litigate the same issue more than once, and that a right or fact that has already been judicially determined by a competent court should be conclusive as to the parties.73 More than being a technicality, the Court has long pronounced this as a fundamental precept designed to promote just, fair and speedy justice.74 This doctrine is set forth in Section 47 of Rule 39 of the Rules of Court, which in its relevant part reads:


Section. 47. Effect of Judgments or Final Orders. — The effect of a judgment or final order rendered by a court of the Philippines, having jurisdiction to pronounce the judgment or final order, may be as follows:


x x x


(b)
In other cases, the judgment or final order is, with respect to the matter directly adjudged or as to any other matter that could have been raised in relation thereto, conclusive between the parties and their successors in interest by title subsequent to the commencement of the action or special proceeding, litigating for the same thing and under the same title and in the same capacity; and


(c)
In any other litigation between the same parties or their successors in interest, that only is deemed to have been adjudged in a former judgment or final order which appears upon its face to have been so adjudged, or which was actually and necessarily included therein or necessary thereto.



In Degayo v. Magbanua-Dinglasan,75 the Court elucidated on the concept and appreciation of conclusiveness of judgment:


Conclusiveness of judgment finds application when a fact or question has been squarely put in issue, judicially passed upon, and adjudged in a former suit by a court of competent jurisdiction. The fact or question settled by final judgment or order binds the parties to that action (and persons in privity with them or their successors-in-interest). and continues to bind them while the judgment or order remains standing and unreversed by proper authority on a timely motion or petition; the conclusively settled fact or question furthermore cannot again be litigated in any future or other action between the same parties or their privies and successors-in-interest, in the same or in any other court of concurrent jurisdiction, either for the same or for a different cause of action. Thus, only the identities of parties and issues are required for the operation of the principle of conclusiveness of judgment.

While conclusiveness of judgment does not have the same barring effect as that of a bar by former judgment that proscribes subsequent actions, the former nonetheless estops the parties from raising in a later case the issues or points that were raised and controverted, and were determinative of the ruling in the earlier case. In other words, the dictum laid down in the earlier final judgment or order becomes conclusive and continues to be binding between the same parties, their privies and successors-in-interest, as long as the facts on which that judgment was predicated continue to be the facts of the case or incident before the court in a later case; the binding effect and enforceability of that earlier dictum can no longer be re-litigated in a later case since the issue has already been resolved and finally laid to rest in the earlier case.76


Before res judicata can apply, the following requisites must be present: (a) the former judgment must be final; (b) it must be rendered by a court having jurisdiction over 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, of subject matter and of cause of action.77


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G.R. No. 220916, June 14, 2021

PEOPLE OF THE PHILIPPINES, Petitioner, v. CAMILO CAMENFORTE AND ROBERT LASTRILLA, Respondents.


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