Degayo v. Magbanua-Dinglasan(2015); Brion, C.J.

G.R. No. 173148

Digest writer: Dodot
Petitioner: Elsa Degayo
Respondents: Cecilia Magbanua-Dinglasan, Johnny Dinglasan, Asuncion Magbanua-Porras, Mariano Pascualito, and
Amado Jr., all surnamed Magbanua
Concept: Judicial Notice
Brief Facts: Degayo and Magbanua-Dinglasan, et al. were contesting the ownership of a disputed area adjoining the
Jalaud River: Degayo was claiming ownership on the theory that the disputed area was an accretion to her own
property; on the other hand, Magbanua-Dinglasan, et al. were claiming ownership on the theory that the disputed
area was an abandoned riverbed which accrued to them, as the owners of the land where the new riverbed ran
through. Magbanua-Dinglasan, et al. filed a complaint for ownership against Degayos tenants (CIVIL CASE NO. 1). After
denying Degayos motion to intervene, the RTC eventually decided in favor of Magbanua-Dinglasan, et al. which
decision attained finality. Meanwhile, Degayo filed a separate case for ownership with damages against MagbanuaDinglasan, et al. (CIVIL CASE NO. 2). Although the RTC decided in favor of Degayo, the CA on appeal reversed, on
the ground that Civil Case No. 1 constituted res judicata, and after taking judicial notice of Civil Case No. 1. The
Supreme Court DENIED the petition for review on certiorari filed by Degayo.
Doctrine: The taking of judicial notice is a matter of expediency and convenience for it fulfills the purpose that the
evidence is intended to achieve, and in this sense, it is equivalent to proof.
General Rule (contents of records of other cases): courts are not authorized to take judicial notice even when such
cases have been tried or are pending in the same court or before the same judge.

Exceptions:
o Close connection with the matter in controversy.
o To determine whether or not the pending case is moot.
Justice

Paras on Judicial Notice (Republic v. CA):

Its own acts and records in the same case;
facts established in prior proceedings in the same case;
authenticity of its own records of another case between the same parties;
files of related cases in the same court;
public records on file in the same court;
record, pleadings or judgment of a case in another court between the same parties or involving one of the
same parties;
record of another case between different parties in the same court.

FACTS:
Antecedents
1.
2.

Controversy between riparian owners (Jalaud River):

1.1. Degayos lot: used to be bounded on the southwest by the Jalaud River
1.2. Magbanua-Dinglasan, et al.s lot: opposite side of the Jalaud River
In the 1970s, the Jalaud River steadily changed its course and moved southwards.
2.1. Magbanua-Dinglasan, et al.s lot decresed in size while the banks adjacent to Degayos lot
gradually increased in land area.
2.1.1. Half of the disputed area, 52,528 sq.m. big, was made up of the original abandoned river bed, while
the other half was made up of the resurfaced area of Magbanua-Dinglasan et al.s lot.
2.2. Degayo and her tenants: believed that the disputed area was an ACCRETION to Degayos lot the
tenants began cultivating and tilling the area with corn and tobacco.
2.3. Magbanua-Dinglasan, et al.: believed that the disputed area was an ABANDONED RIVERBED thus,
rightfully belongs to them, to compensate for the portion of their lot over which the Jalaud River presently ran.

The Case
3.

(CIVIL CASE NO. 1)

3.1. Magbanua-Dinglasan, et al. filed a complaint for ownership and damages against Degayos
tenants (RTC of Iloilo).
3.1.1. Degayo sought to intervene her motion was denied.
3.1.1.1.
NOTE: Degayo never filed anything to question the interlocutory order denying her
motion to intervene.
3.2. Notwithstanding the denial of her motion to intervene (and as Civil Case No. 2 was pending), Degayo

participated in the proceedings as a witness for the defense (her tenants).

3.2.1. During her direct examination, she testified on the same matters and raised the same arguments she
alleged in her complaint in Civil Case No. 2.
3.3. RTC: rendered a decision in favor of Magbanua-Dinglasan, et al.
3.3.1. Although Degayos tenants filed an appeal, they failed to file an appeal brief causing the dismissal
of their appeal.
3.3.2. The decision became final and executory on 6 August 1999.
4. (CIVIL CASE NO. 2)
4.1. Degayo filed a complaint for declaration of ownership with damages (RTC of Iloilo).
4.1.1. Degayo stressed that the disputed area was an accretion to her lot.
4.2. RTC: found in favor of Degayo declared the disputed area as an accretion of Degays lot.
4.2.1. After the RTC denied their motion for reconsideration, Magbanua-Dinglasan, et al. filed an appeal
w/ the CA
4.3. CA: granted the appeal and reversed and set aside the RTC.
4.3.1. The CA noted that the disputed area was an abandoned riverbed that rightfully belonged to MagbanuaDinglasan, et al.
4.3.2. ***The CA also noted that the decision in Civil Case No. 1 was CONCLUSIVE to the title of
the thing (Conclusiveness of Judgment).
4.4. After the CA denied her motion for reconsideration, Degayo filed a petition for Review on Certiorari
(R45) with the SC.
ISSUE:
1. Does the Decision in Civil Case No. 1 constitute res judicata? (YES.)
2. ***Was the CA correct in taking judicial notice of Civil Case No. 1? (YES.)***
RATIO:
1. The Decision in Civil Case No. 1 constituted res judicata.
Res judicata: a matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment.

Final judgment on the merits by a court of competent jurisdiction is conclusive of the rights of the parties or
their privies in all later suits on points on matters determined in the former suit.

Parties should not be permitted to litigate the same issue more than once. (There should be an end to
litigation.)
o Practical concern: overflowing dockets, scarce judicial resources, efficiency. (Salud v. CA)
o Rights and liabilities once established should remain fixed.

Most important purpose of res judicata: provide repose for both the party litigatnts
and the public.

Res judicata thus encourages reliance on judicial decision, bars vexatious litigation, and frees
the courts to resolve other disputes.
What of Judicial error?

Should be corrected through appeals NOT repeated suits.

Relitigation: risk of inconsistent results which should be preferred?

o Since there is no reason to suppose that the subsequent determinations are necessarily more
accurate, the first should be left undisturbed.
Basis in remedial law: R39, Sec. 47.

Bar by former judgment (Claim preclusion)

Conclusiveness of judgment (Issue preclusion; collateral estoppel)

o Identities of parties and issues
o Facts or questions settled by final judgment/order binds the parties (and persons in privity with them,
and successors-in-interest) cannot be relitigated

Parties estopped from raising the same issues raised, controverted, determinative of ruling.
Case at bar:

Civil Case No. 1: adjudicated on the merits, attained finality, decided by competent court.

Identity of parties in both actions absolute identity of parties is NOT required, shared identity of
interest is sufficient to invoke the coverage of res judicata.
On contention that Degayo could not be bound because she had not been made a party in Civil Case No. 1:

Real litigant may be held bound as a party even if NOT formally impleaded because he had his day in court
and because her substantial rights were not prejudiced. (Torres v. Caluag)
o Degayo had the fullest opportunity to ventilate her accretion claim in Civil Case No 1:

Asserted that she inherited her lot from her parents, and had been in possession since 1954.


Asserted that the disputed area occupied by her tenants was the result of accretion.
These are the same allegations asserted by Degayo in Civil Case No. 2.

These allegations had already been considered and evaluated in Civil Case No. 1.
Community of interest between Degayo and her tenants (respondents in Civil Case No. 1).
o TEST: whether the success or failure of one party materially affects the other.

Degayos rights over the disputed area is predicated on the same defenses that her tenants
interposed in Civil Case No. 1.

Both claims emanate from a singular fundamental allegation of accretion.

The disputed area in Civil Case No. 1 and Civil Case No. 2 are one and the same.
o Degayo admitted as much in her petition.
Question of ownership of the disputed area had been unequivocally settled in Civil Case No. 1.
o Abandonment of river bed NOT accretion.
o

SC: agreed with the uniform view of the CA, on the application of conclusiveness of judgment to the present case.
2. ***The CA may take judicial notice of Civil Case No. 1.***
The SC stated that [t]he taking of judicial notice is a matter of expediency and convenience for it fulfills the purpose
that the evidence is intended to achieve, and in this sense, it is equivalent to proof. (Land Bank of the Philippines v.
Sps. Banal)
General Rule (contents of records of other cases): courts are not authorized to take judicial notice even when
such cases have been tried or are pending in the same court or before the same judge.

Exceptions:
o Close connection with the matter in controversy.
o To determine whether or not the pending case is moot.
Moreover, Degayos objection to the action of the CA is merely technical:

Degayo herself repeatedly referred to Civil Case No. 1 in her pleadings, her appellees brief before
the CA, and her petition for review before the SC.
o Complaint: motion to intervene in [Civil Case No. 1], which was denied by the Court
o Appellees brief: [Civil Case No. 1] was for recovery of ownership and possession with damages

Existence of Civil Case No. 1 was jointly stipulated by the parties and mentioned by the court a
quo in its decision.
SC: Under the circumstances, the CA could certainly take judicial notice of the finality of a judgment in Civil Case No.
16047. There was no sense in relitigating issues that have already been passed upon in a previous civil case. That was
all that was done by the CA in decreeing the dismissal.
Justice Paras on Judicial Notice (Republic v. CA):
A court will take judicial notice of its own acts and records in the same case, of facts established in prior
proceedings in the same case, of the authenticity of its own records of another case between the same parties,
of the files of related cases in the same court, and of public records on file in the same court. In addition judicial
notice will be taken of the record, pleadings or judgment of a case in another court between the same parties or
involving one of the same parties, as well as of the record of another case between different parties in the same
court.

DISPOSITIVE: WHEREFORE, premises considered, we DENY the petition for lack of merit. Costs against the petitioner