Doctrine of Conclusiveness of Judgment Flashcards
What is the doctrine of conclusiveness of judgment?
The doctrine of conclusiveness of judgment is otherwise known as “preclusion of issues” or “collateral estoppel”.
Conclusiveness of judgment is a species of res judicata and it applies where there is identity of parties in the first and second cases, but there is no identity of causes of action. 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. Thus, if a particular point or question is in issue in the second action, and the judgment will depend on the determination of that particular point or question, a former judgment between the same parties or their privies will be final and conclusive in the second if that same point or question was in issue and adjudicated in the first suit. Identity of cause of action is not required but merely identity of issue.
This concept is embodied in the third paragraph of Rule 39, Section 47 of the Rules of Civil Procedure:
Section 47. Effect of judgments or final orders.—The effect of a judgment or final order rendered by a court of the Philippines, having jurisdiction to pronounce the judgment or final order, may be as follows:
x x x
(c) 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.
(Tala Realty Services Corp., Inc. v. Banco Filipino Savings and Mortgage Bank, G.R. No. 181369, June 22, 2016)
