G.R. No. L-15253; October 31, 1960
THEODORE LEWIN, petitioner, vs. EMILIO GALANG, in his official capacity as Commissioner of Immigration, respondent.

FACTS

Petitioner Theodore Lewin, a U.S. citizen, was classified as an alien permanent resident in the Philippines with an Immigration Certificate of Residence issued on April 16, 1951. On September 16, 1953, he obtained a Re-entry Permit valid until March 16, 1954, preparatory to a visit to the United States. While in the U.S., his American passport was taken by U.S. authorities, preventing his return to the Philippines before his Re-entry Permit expired. His passport was returned in August 1955, and a new one was issued in 1956. However, he could not return because his permit had expired and the Philippine Department of Foreign Affairs had issued instructions prohibiting the issuance of a visa to him without prior authorization. He eventually secured admission as a temporary visitor for nine days but maintained his intention to reside permanently. The respondent Commissioner of Immigration threatened to arrest and deport him upon the expiration of his temporary stay. Lewin filed a petition for declaratory relief, seeking a declaration that he had not lost his permanent resident status and an injunction against his arrest and deportation. The Court of First Instance of Manila granted the petition and issued a preliminary injunction. The respondent appealed, arguing, among other defenses, that the petition was barred by res judicata due to a prior habeas corpus case (Special Proceeding No. 28409) filed by Lewin before the same court and judge, which was dismissed. In that prior case, Lewin alleged substantially the same facts regarding his permanent residence, his temporary visit to the U.S., and his inability to return due to circumstances beyond his control.

ISSUE

Whether the petition for declaratory relief is barred by the principle of res judicata due to a final judgment in a prior habeas corpus case between the same parties involving the same facts and cause of action.

RULING

Yes. The Supreme Court reversed the decision of the Court of First Instance and dismissed the complaint. The Court held that the present action for declaratory relief is barred by res judicata. The prior habeas corpus case involved the same parties, the same facts (Lewin’s claim of permanent residence, his temporary visit, and his inability to return), and the same cause of action (the determination of his right to remain in the Philippines as a permanent resident). The dismissal of the habeas corpus petition constituted a final judgment on the merits. The Court emphasized that the principle of res judicata applies to prevent relitigation of the same issue. It further noted that public policy and the interest of uniformity in decisions demand that the final decision in the habeas corpus case be respected, as allowing the subsequent contrary decision would result in two conflicting final judgments on the same set of facts between the same parties. The Court found it its duty to consider the prior final decision to avoid such an anomaly.