Republic v Ramon Yu

Conclusiveness of Judgment (R39 S47)

Facts:
1. In a previous case (Valdehueza v. Republic), SC affirmed the judgment of expropriation
and that Valdehueza cannot recover possession of their land but may only demand a fair
market value
2. In another case, Yu vs. Republic, the CA invalidated Valdehuezas sale of the expropriated
property to Ramon Yu and held that Yu is not a purchaser in good faith. There being no
appeal to this decision, it became final and executory
3. Ramon Yu then filed another complaint seeking the reversion of the expropriated
property. Republic denied Yus right to reacquire title on ground of Res Judicata. RTC
dismissed Yus case, but CA reversed it and remanded the case back to RTC.
4. Hence, this petition
Issue: W/N Yus case is barred by res judicata
Held: Yes.
Ratio:
Republic argues that the case is barred by res judicata because the decision in Yu vs. Republic
held that Yu does not have a right to assert ownership over the property, the sale being
invalidated by the CA. Further, the expropriation is absolute and unconditional that the fact that
the nearby lots were sold or reverted would not necessarily give Yu a right to revert the
expropriated property.
Yu argues that the case is not barred by res judicata because the government essentially
abandoned the properties, which constitutes a new cause of action. Further, the determination
of their right to reacquire the property needs to be decided on a full-blown trial.
Court disagrees with Yu. The case is barred by res judicata by conclusiveness of judgment.
Refresher: There is res judicata when:
1. The previous judgment must be final
2. Rendered by a court with proper jurisdiction over both the subject matter and persons
3. Must be a judgment on the merits
4. And there must be identity of parties, subject matter, and cause of action.
While the first three are present, only the identity of causes of action is the issue. The court then
differentiated Conclusiveness of Judgment (R39 S47c) and Bar by Prior Judgment (R39 S47b).
There is Bar by prior judgment when there is identity of parties, cause of action, and subject
matter. There is conclusiveness of judgment when even if there is no identity of cause of action,
the previous judgment is conclusive on the subject matter raised therein.

Conclusiveness of judgment applies in this case. Given that Yu is raising his right of ownership
by virtue of the sale, he cannot again raise it because the previous final judgment of the CA
rendered the sale invalid. Having no proper right to base his claim, Yu has no legal personality
to file the action of recovery of ownership. There being no legal personality, Yu is not actually a
real party in interest.
Ruling: CA reversed, case is barred by res judicata