GR 35903; (October, 1932) (Digest)
G.R. No. 35903 ; October 27, 1932
PRUDENCIA CHUA TAN, ET AL., plaintiffs-appellants, vs. LUCIA DEL ROSARIO, administratrix of the estate of the deceased, Chua Toco, defendant-appellee.
FACTS
The plaintiffs, presumptive heirs of the late Chua Piaco, filed an action against the defendant, the administratrix of the intestate estate of Chua Toco, seeking partition of funds amounting to P77,118.90 (allegedly from a P20,000 deposit) and its products, claiming that the original sum belonged to Chua Piaco and was delivered to his adopted son, Chua Toco, by way of trust. The defendant raised the defense of res judicata, citing a prior final judgment in Civil Case No. 25797 ( G.R. No. 26258 ), where Benedicta Santa Juana, as administratrix of Chua Piaco’s estate, sued Lucia del Rosario, as administratrix of Chua Toco’s estate, for an accounting of the same funds based on the same trust allegation. That prior complaint was dismissed, and the dismissal was affirmed by the Supreme Court.
ISSUE
Whether the prior judgment in Civil Case No. 25797 constitutes res judicata and bars the present action.
RULING
Yes, the prior judgment is res judicata. The Court applied the doctrine of res judicata under Sections 306 and 307 of the Code of Civil Procedure. All necessary elements are present: (1) There is privity between the parties, as the plaintiff administratrix in the prior case was the legal representative of the intestate estate of Chua Piaco and thus represented the interests of the heirs (the present plaintiffs); (2) There is identity of cause of action, as both cases are predicated on the same alleged right arising from an implied trust over the same funds; (3) There is identity of subject matter; and (4) There is identity of the central issue—the ownership of the funds—which was necessarily and impliedly decided in the prior case when the complaint was dismissed. The relief sought (accounting vs. partition) is different, but the judgment operates as an estoppel as to the matter actually and directly in issue and adjudged. The trial court’s judgment dismissing the complaint was affirmed.
AI Generated by Armztrong.