ROWENA PADILLA-RUMBAUA, PETITIONER-APPELLANT, VS. EDWARD PADILLA-RUMBAUA, RESPONDENT-APPELLEE.

Padilla-Rumbaua versus Padilla-Rumbaua

The Case

This is the case of Rowena Padilla-Rumbaua versus Edward Padilla-Rumbaua. Rowena, the petitioner-appellant, brought an action for the declaration of absolute nullity of her marriage to Edward, the respondent-appellee. She anchored her second attempt on her own psychological incapacity and on the alleged absence of a solemnizing officer and of a marriage ceremony. The case matters because it shows how the doctrine of res judicata, the rule that a matter once finally adjudged cannot be litigated again, closes the door on a party who tries to relitigate the same marriage by changing the ground and the theory.

Procedural History

Rowena first filed a complaint for declaration of nullity of marriage before the Regional Trial Court of Bayombong, Nueva Vizcaya, Branch 29, grounded on Edward's alleged psychological incapacity. The trial court nullified the marriage. The Republic of the Philippines, through the Office of the Solicitor General, appealed. The Court of Appeals reversed and set aside the trial court's decision and denied the nullification. It later denied Rowena's motion for reconsideration. Rowena then went up to the Supreme Court on a petition for review on certiorari, but the Supreme Court denied the petition and affirmed the Court of Appeals. That first decision became final.

Rowena then filed a second petition for declaration of absolute nullity of marriage before the Regional Trial Court of Bayombong, Nueva Vizcaya, this time docketed as Civil Case No. 1140. The trial court, Branch 37, dismissed the case on the ground of res judicata. It denied her motion for reconsideration. Rowena appealed to the Court of Appeals, which denied the appeal and affirmed the trial court's order. The present decision is the Court of Appeals' ruling on that appeal.

Facts

Rowena and Edward were married. Rowena filed a complaint for declaration of nullity of their marriage before the Regional Trial Court of Bayombong, Nueva Vizcaya, Branch 29, on the ground of Edward's alleged psychological incapacity to exercise the essential obligations of marriage. The trial court granted the petition and nullified the marriage.

The Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the trial court and denied the nullification of the marriage. The Court of Appeals also denied Rowena's motion for reconsideration. Rowena elevated the matter to the Supreme Court, which denied her petition and affirmed the Court of Appeals. The decision in that first case became final.

After that finality, Rowena filed a second petition for declaration of absolute nullity of marriage. This time she alleged that she herself was suffering from psychological incapacity to comply with her marital obligations, citing a psychological evaluation showing a narcissistic personality disorder present since childhood, which she described as permanent and incurable. She also insisted that there was no solemnizing officer and no marriage ceremony during their secret marriage, so that one of the formal elements of marriage was lacking. The trial court dismissed the second petition on the ground of res judicata, and the Court of Appeals affirmed.

Issues

• Whether or not the second petition for declaration of nullity of marriage is barred by res judicata in its concept as a bar by prior judgment.
• Whether or not the change of ground, from the husband's psychological incapacity in the first case to the wife's psychological incapacity and the absence of a solemnizing officer in the second case, defeats the identity of causes of action.

Applicable Provisions

Section 47, paragraph b, of Rule 39 of the Rules of Court provides:

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 x x x x x x (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 raised 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; and

This provision is the textual basis for the bar by prior judgment, making a final order conclusive not only on what was adjudged but on every matter that could have been raised in the first action.

Ruling

On the first issue, the Court of Appeals held that the appeal has no merit. It ruled that a party cannot, by varying the form of action or adopting a different method of presenting his case, escape the operation of the principle that one and the same cause of action shall not be twice litigated. Applying Section 47, paragraph b, of Rule 39, the Court of Appeals held that res judicata as a bar by prior judgment requires the concurrence of four requisites: the former judgment is final; it is rendered by a court having jurisdiction over the subject matter and the parties; it is a judgment or an order on the merits; and there is between the first and second cases identity of parties, of subject matter, and of causes of action. The Court of Appeals found all four present, since the first case involved the denial, with finality, of Rowena's petition for declaration of nullity of the same marriage, and the second case is likewise an action for the declaration of nullity of that same marriage.

On the second issue, the Court of Appeals held that it is of no moment that the earlier case was premised on Edward's alleged psychological incapacity while the second case is grounded on Rowena's alleged psychological incapacity plus the alleged absence of a solemnizing officer or marriage ceremony. The Court of Appeals explained that res judicata as a bar by former judgment is an absolute bar to the subsequent action, since the judgment is conclusive not only as to the matters offered and received to sustain the judgment but also as to any other matter which might have been offered for that purpose and which could have been adjudged thereon. The parties should have ventilated all matters and relevant issues in the first case.

Doctrine

A Bar candidate should retain these rules. First, res judicata as a bar by prior judgment requires four requisites: a final former judgment; rendered by a court with jurisdiction over the subject matter and the parties; a judgment or order on the merits; and identity of parties, subject matter, and causes of action between the first and second cases. Second, a party cannot, by varying the form of action or adopting a different method of presenting the case, escape the rule that one and the same cause of action shall not be twice litigated. Third, under Section 47, paragraph b, of Rule 39, the final judgment is conclusive not only as to the matter directly adjudged but as to any other matter that could have been raised in relation thereto, so a new ground or a new theory that could have been pleaded in the first case is barred.

Disposition

The Court of Appeals denied the appeal and affirmed the trial court's order dismissing the second petition for declaration of nullity of marriage on the ground of res judicata.

Remember This

The single line worth memorizing is that a party cannot escape res judicata by varying the form of action or changing the ground, because a final judgment bars not only what was adjudged but every matter that could have been raised. Examiners like to use this case to test the requisites of res judicata as a bar by prior judgment and the rule against splitting a single cause of action for the nullity of a marriage.