G.R. No. L-18464 December 29, 1962
ARING (BAGOBA), ET AL., plaintiffs-appellants, vs. JOSE (NAKAMURA) ORIGINAL, defendant-appellee.

FACTS

On July 27, 1955, Jose (Nakamura) Original filed a complaint (Civil Case No. 765) to recover ownership and possession of two parcels of land from Aring (Bagoba), et al. Original alleged he was the acknowledged natural son and sole heir of Obot (Bagoba), the original owner, and that the defendants had fraudulently obtained titles to the lands. The defendants, in their answer, expressed uncertainty if the plaintiff was the same Jose Original, believed killed after WWII, but did not categorically deny his identity or heirship. After trial, the court ruled in favor of Original, declaring him the owner and ordering the cancellation of the defendants’ titles and the delivery of possession to him. This decision became final and executory, and Original was placed in possession.
On January 11, 1961, over four years later, Aring (Bagoba), et al., instituted a new action (Civil Case No. 3465) seeking to annul the prior decision and recover the same lands. They alleged the judgment was obtained through fraud, that Original had no cause of action, and that the court lacked jurisdiction over one lot. Original moved to dismiss on grounds of res judicata, arguing the fraud alleged was not extrinsic, and that plaintiffs were estopped. The trial court dismissed the case, holding the action was barred by a prior judgment.

ISSUE

Whether the present action for annulment of judgment and recovery of title is barred by the principle of res judicata.

RULING

Yes, the action is barred by res judicata. The Supreme Court affirmed the dismissal, finding all elements of res judicata present: (1) the judgment in Civil Case No. 765 was final; (2) it was rendered by a court of competent jurisdiction; (3) it was a judgment on the merits; and (4) there was identity of parties, subject matter, and cause of action between the two cases. While the technical grounds for the new action differed, in substance both suits aimed at recovering title and possession of the identical properties, satisfying the identity requirement.
The Court rejected the claim of extrinsic fraud. Original had expressly alleged in the prior case that he was the acknowledged natural child and heir of Obot (Bagoba), which the defendants did not squarely dispute but only questioned based on unverified wartime information. Original successfully proved his identity at trial. Any alleged fraud was intrinsic, pertaining to matters litigated and adjudicated, not extrinsic fraud that prevented a party from presenting their case. The jurisdictional challenge was also without merit. The prior action was not a petition for review of a land decree but an action for annulment of title based on fraud, which was within the court’s competence. Consequently, the prior judgment constitutes an absolute bar to the re-litigation of the same claim.