ii. Conclusiveness of Judgment

Effects of Judgments IN REM

In case of a judgment or final order:

• Against a specific thing; or
• In respect to the probate of a will; or
• The administration of the estate of a deceased person; or
• In respect to the personal, political, or legal condition or status of a particular person or his relationship to another (Example: naturalization, adoption, and annulment of marriage)

The judgment or final order is CONCLUSIVE upon the title to the thing, the will or administration or the condition, status or relationship of the person.

Exception: The probate of a will or granting of letters of administration shall only be PRIMA FACIE evidence of the death of the testator or intestate. (Rule 39, Sec. 47)

Effects of Judgments IN PERSONAM

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 missed 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. (RES JUDICATA or BAR BY PRIOR JUDMENT)

Q: Spouses X filed 2 Civil Cases regarding a parcel of land. The first case was a complaint for specific performance. The RTC’s decision, which was upheld by the CA, granted the Spouses X’s prayer to declare the sale over the subject property made by Corporation A to another null and void, as well as ordering Corporation A to execute a deed of conveyance in favor of petitioners Sps. Pozon.

Subsequently, Y filed a Petition for Queiting of Title regarding the same parcel of land. The RTC and CA ruled in favor of Y’s ownership. Hence, Spouses X argued that there were two previously decided cases resolved in favor of them, and it touched upon the same subject matter as Y’s Petition for Queiting of Title. That the specific case, specifically, is conclusive upon the court a quo with respect to their ownership over the subject property. Is the resolution of the specific performance case in favor of Spouses X conclusive upon the court with regards to their ownership?

A: NO. The right of ownership over the subject property was not at all an issue in the Specific Performance Case. In fact, in the said Decision, it was made clear that petitioners Sps. X did not pray that they be declared the owners of the subject property. Instead, their prayer was limited only to the nullification of the sale

Further, it must be emphasized that the Specific Performance Case did not dwell whatsoever on the issues surrounding respondent Y's claim of ownership over the subject property. In fact, it must be stressed that Y was not even impleaded in the Specific Performance Case.

Lastly, the Specific Performance Case invoked by petitioners Sps. X in the instant case, is an action in personam. And being a judgment in personam, the judgment is binding ONLY upon the parties properly impleaded therein. (Spouses Pozon v. Lopez, G.R. No. 210607 (Resolution), [March 25, 2019])

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. (ESTOPPEL BY JUDGMENT OR CONCLUSIVENESS OF JUDGMENT)

Judgment is deemed CONCLUSIVE when the issues actually and directly resolved in a former suit cannot again be raised in any future case between the same parties involving a different cause of action.

Res Judicata v Conclusiveness of Judgment

Res judicata (meaning, a “matter adjudged”) is a fundamental principle of law which precludes parties from re-litigating issues actually litigated and determined by a prior and final judgment. There is a bar by prior judgment where there is identity of parties, subject matter, and causes of action between the first case where the judgment was rendered and the second case that is sought to be barred. There is conclusiveness of judgment, on the other hand, where there is identity of parties in the first and second cases, but no identity of causes of action. (De Leon v Dela Llana, G.R. No. 212277, 2015)

Estoppel by Judgment or Conclusiveness of Judgment

Any right, fact or matter in issue which has been directly adjudicated upon or is necessarily involved in the determination of the action by a competent court is conclusively settled by the judgment or final order and CANNOT be litigated again by the parties and their privies.

Generally, decisions in administrative cases are not binding on criminal proceedings. Thus, an absolution from a criminal charge is not a bar to an administrative prosecution or vice versa. However, this case does not involve and administrative charge stemming from the same set of facts involved in the criminal proceeding. The DARAB case involves a determination of whether there exists a tenancy relationship between X and Y, while the criminal case involves determination of whether X committed theft. However, the tenancy relationship is a factor in determining all the elements of theft. Hence, findings of fact of administrative agencies in the exercise of quasi-judicial powers are entitled to respect if supported by substantial evidence. (People v Ligtas G.R. 200751, August 17, 2015)