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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.

AT A GLANCE:

The principle of res judicata means “a matter adjudged” or a thing judicially acted upon or decided or settled by judgment.

In litigation, there comes a point where disputes must come to an end. The law recognizes this through the principle of res judicata, which bars parties from re-litigating matters that have already been resolved with finality. 

What is Res Judicata?

The principle of res judicata means “a matter adjudged” or a thing judicially acted upon or decided or settled by judgment. The essential elements of res judicata are: 

1. the judgment sought to bar the new action must be final; 
2. the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; 
3. the disposition of the case must be a judgment on the merits; and 
4. there must be as between the first and second actions, identity of parties, subject matter, and causes of action. (Batan v. Mines and Geosciences Bureau, G.R. No. 277730, November 4, 2025)

Two Concepts of Res Judicata

In Aguila v. . Perfect Dimension Corp., G.R. No. 243317, August 4, 2025, the Supreme Court recognized the two distinct concepts of Res judicata:

1. bar by prior judgment as enunciated in Rule 39, Section 47 (b); and 
2. conclusiveness of judgment in Rule 39, Section 47 (c).

Bar by Prior Judgement

Section 47(b), Rule 39 of the Rules on Civil Procedure, states:

“(b) 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.”

As explained by the Supreme Court in the case of Spouses Ocampo v. Heirs of Dionisio, G.R. No. 191101, October 1, 2014, there is “bar by prior judgment” when, as between the first case where the judgment was rendered and the second case that is sought to be barred, there is identity of parties, subject matter, and causes of action. In this instance, the judgment in the first case constitutes an absolute bar to the second action. 

Otherwise put, the judgment or decree of the court of competent jurisdiction on the merits concludes the litigation between the parties, as well as their privies, and constitutes a bar to a new action or suit involving the same cause of action before the same or other tribunal.

Conclusiveness of Judgment

Also discussed in Spouses Ocampo v. Heirs of Dionisio, where there is identity of parties in the first and second cases, but no identity of causes of action, the first judgment is conclusive only as to those matters actually and directly controverted and determined and not as to matters merely involved therein. This is the concept of res judicata known “conclusiveness of judgment.” 

Stated differently, any right, fact or matter in issue directly adjudicated or necessarily involved in the determination of an action before a competent court in which judgment is rendered on the merits is conclusively settled by the judgment therein and cannot again be litigated between the parties and their privies whether or not the claim, demand, purpose, or subject matter of the two actions is the same.

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Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 09175772207/ 09778050020.

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