Asis vs. Calignawan

A final judgment on the merits by a court of competent jurisdiction is conclusive between the same parties and their privies on the same issue directly adjudicated or necessarily involved therein, barring its re-litigation in a subsequent action under the principle of res judicata by conclusiveness of judgment.

The dispute originated from properties (Lot Nos. 581 and 2064) in Tacloban City registered under the names of sisters Romana Engao and Angeles Engao-Calignawan. Rosello Calignawan, claiming to be Angeles' son and heir, filed a complaint for declaration of nullity of documents (Deed of Adjudication, Deed of Consolidation, Extrajudicial Settlement) and partition, alleging his signature on these documents was forged. He also asserted rights based on a Deed of Donation purportedly executed by Angeles in his favor in 1984. The petitioners, heirs of Felipe Engao (brother of Angeles), challenged Rosello's filiation and the validity of the Deed of Donation.

• Nature of the Action: A civil case for declaration of nullity of documents (Deed of Adjudication, Deed of Consolidation, Extrajudicial Settlement), partition, and damages, with a core dispute over the validity of a Deed of Donation.
• The Parties and Properties: The subject properties were registered under sisters Romana Engao and Angeles Engao-Calignawan. Petitioners are the heirs of Felipe Engao (Romana's son and Angeles' brother). Respondents are the heirs of Rosello Calignawan, who claimed to be Angeles' son.
• The Deed of Donation: Rosello claimed Angeles executed a Deed of Donation in his favor on May 25, 1984. Petitioners challenged its validity, alleging forgery and that Angeles was physically unfit to travel for its notarization.
• The Partition Documents: In 1982, a Deed of Adjudication and Deed of Consolidation were executed, purportedly by Rosello, Evangeline, Erma, Felicitation, and Cesar, to partition the properties. Rosello claimed his signature was forged. These were later superseded by an Extrajudicial Settlement in 1985.
• RTC of Burauen Decision: In a separate case (Civil Case No. B-92-10-461) for recovery of ownership based on the same Deed of Donation, the RTC of Burauen upheld the donation's validity. This decision was affirmed by the CA and Supreme Court, becoming final.
• RTC of Tacloban Decision: In the instant case, the RTC of Tacloban declared the Deed of Donation null and void, citing doubts about its execution and Angeles' capacity. It also nullified the partition documents and ordered the reinstatement of the original titles.
• Court of Appeals Decision: The CA reversed the RTC of Tacloban. It declared the partition documents void as contracts on future inheritance but held the Deed of Donation valid, applying res judicata based on the final RTC Burauen judgment.

• Forum Shopping: Petitioners argued that Rosello committed forum-shopping by splitting his cause of action and filing two separate complaints (for nullity of documents and for recovery of ownership) based on the same Deed of Donation.
• Procedural Liberality: Petitioners contended the CA erred in admitting respondents' belated appellant's brief without sufficient justification, exercising unwarranted liberality.
• Jurisdictional Precedence: Petitioners maintained that the RTC of Tacloban assumed jurisdiction first and its decision should take precedence over the later RTC Burauen decision under the doctrine of non-interference.
• Estoppel: Petitioners argued respondents were estopped from challenging the RTC of Tacloban's jurisdiction after their predecessor had filed both cases.

• No Forum Shopping: Respondents countered that the two complaints had distinct causes of action (nullity vs. recovery of ownership) and reliefs. The issue of forum-shopping was also raised too late on appeal.
• Justifiable Liberality: Respondents argued the belated filing of the appellant's brief was due to their former counsel's gross negligence, which should not prejudice them, justifying the CA's liberal application of the rules.
• Res Judicata: Respondents argued that the validity of the Deed of Donation was already conclusively settled with finality by the RTC Burauen, as affirmed by the Supreme Court, barring its re-litigation under res judicata.

• Forum Shopping: Whether Rosello Calignawan committed forum-shopping by filing two separate complaints based on the same Deed of Donation.
• Procedural Liberality: Whether the Court of Appeals erred in admitting the respondents' belated appellant's brief.
• Res Judicata: Whether the principle of res judicata (conclusiveness of judgment) applies to bar the re-litigation of the validity of the Deed of Donation.
• Jurisdictional Precedence: Whether the RTC of Tacloban's decision should prevail over the RTC of Burauen's final decision.

• Forum Shopping: Rosello indeed committed forum-shopping, as the complaints shared identity of parties, sought similar reliefs (reconveyance based on the Deed), and a judgment in one would constitute res judicata in the other. However, the petitioners waived this defense by failing to raise it in their answer or a motion to dismiss before the RTC, raising it only on appeal.
• Procedural Liberality: The CA did not err in admitting the belated brief. The discretion to grant extensions and admit late filings is sound, and the reason provided (gross negligence of prior counsel) was satisfactory. In civil cases, courts may relax procedural rules to serve the interests of justice and achieve a complete resolution on the merits.
• Res Judicata: The principle of res judicata in the concept of conclusiveness of judgment applies. All elements were present: (1) a final judgment (RTC Burauen, affirmed by SC); (2) by a court of competent jurisdiction; (3) a judgment on the merits; and (4) identity of parties and issues (validity of the Deed of Donation). The final judgment conclusively settled the Deed's validity, barring its re-litigation.
• Jurisdictional Precedence: The argument that the RTC of Tacloban's decision should take precedence is untenable. The final and immutable judgment of the RTC Burauen, as affirmed by the Supreme Court, must be respected. The doctrine of non-interference does not apply to override a final judgment.

• Res Judicata (Conclusiveness of Judgment) — A final judgment on the merits by a court of competent jurisdiction is conclusive upon the parties and their privies in a subsequent case involving the same parties and the same issue directly adjudicated or necessarily involved in the prior action. The Court applied this doctrine, finding that the validity of the Deed of Donation had been conclusively settled in a prior final case (G.R. No. 188676), barring its re-litigation.
• Waiver of Defenses/Objections — Under Section 1, Rule 9 of the Rules of Court, defenses and objections not pleaded in a motion to dismiss or in the answer are deemed waived. The Court applied this to hold that the petitioners waived the defense of forum-shopping by not raising it at the earliest opportunity.

• "By the operation of res judicata in the concept of conclusiveness of judgment, We hold that the Deed of Donation is valid." — This succinctly states the core application of the doctrine to the central factual dispute.
• "We will not tolerate or turn a blind eye to the procedural lapses committed in the course of the proceedings... Nonetheless, when the circumstances necessitate and in the interest of substantial justice, courts may relax these procedural rules and be liberal in their application if only to finally settle the issues on the merits." — This passage articulates the Court's balancing act between procedural rigor and substantial justice.

• Heirs of Felipe Engao vs. Rosello Calignawan, G.R. No. 188676 — The final and executory Supreme Court Resolution which affirmed the RTC Burauen's decision upholding the Deed of Donation. This was the controlling precedent that triggered the application of res judicata.
• Taar v. Lawan, 820 Phil. 49 (2017) — Cited to outline the four elements of res judicata.
• Levi Strauss & Co. v. Blancaflor, 785 Phil. 560 (2016) — Cited for the principle that motions for extension of time to file briefs are not granted as a matter of right and require good and sufficient cause.

• Article 1347, New Civil Code — Cited by the CA to declare void the Deed of Adjudication and Deed of Consolidation as contracts involving future inheritance.
• Section 1, Rule 9, Rules of Court — Provides that defenses and objections not pleaded in a motion to dismiss or in the answer are deemed waived. Applied to the forum-shopping defense.
• Section 12, Rule 44, Rules of Court — Governs extensions of time for filing briefs, requiring good and sufficient cause. Applied to the issue of admitting the belated appellant's brief.

Perlas-Bernabe, SAJ. (Chairperson), Hernando, Inting, Gaerlan, and Rosario, JJ.

N/A. The decision was unanimous.