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  • 121 Bachrach v. CA

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    Fatima Areej
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    The Supreme Court ruled that the doctrine of res judicata did not apply to bar Bachrach Corporation's specific performance case, despite a prior unlawful detainer case. While the first three elements of res judicata were met, the fourth element requiring identity of subject matter and causes of action was not. The subject matter and causes of action in the two cases were different - the unlawful detainer case focused on a lease contract violation, while the specific performance case centered on an alleged compromise agreement and its breach. Therefore, different evidence was needed for each case, and res judicata did not prevent the specific performance case from proceeding.

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    The Supreme Court ruled that the doctrine of res judicata did not apply to bar Bachrach Corporation's specific performance case, despite a prior unlawful detainer case. While the first three elements of res judicata were met, the fourth element requiring identity of subject matter and causes of action was not. The subject matter and causes of action in the two cases were different - the unlawful detainer case focused on a lease contract violation, while the specific performance case centered on an alleged compromise agreement and its breach. Therefore, different evidence was needed for each case, and res judicata did not prevent the specific performance case from proceeding.

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    142 views2 pages

    121 Bachrach v. CA

    Uploaded by

    Fatima Areej
    The Supreme Court ruled that the doctrine of res judicata did not apply to bar Bachrach Corporation's specific performance case, despite a prior unlawful detainer case. While the first three elements of res judicata were met, the fourth element requiring identity of subject matter and causes of action was not. The subject matter and causes of action in the two cases were different - the unlawful detainer case focused on a lease contract violation, while the specific performance case centered on an alleged compromise agreement and its breach. Therefore, different evidence was needed for each case, and res judicata did not prevent the specific performance case from proceeding.

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    © All Rights Reserved
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    of 2

    AREEJ

    CASE NO. 121


    RES JUDICATA
    Bachrach Corporation v. CA, 296 SCRA 487

    FACTS: Bachrach Corporation entered into two lease contracts with the Philippine government covering 2 areas. Philippine Ports
    Authority (PPA) issued a Memorandum increasing the rental rates of Bachrach who refused to pay. Thus, PPA initiated unlawful
    detainer proceedings (hereinafter ejectment case) before the MeTC against Bachrach for non-payment of rent. MeTC ordered the
    eviction of Bachrach from the leased premises. RTC affirmed in toto. Bachrach filed a petition for review with the CA, which affirmed
    RTC’s decision. CA denied Bachrach’s MR. CA’s decision in the ejectment suit became final and executory

    Meanwhile, while the MR was yet pending with the CA, Bachrach filed a case for specific performance (hereinafter specific
    performance case) against PPA for refusing to honor a compromise agreement said to have been perfected between Bachrach and
    PPA. Bachrach filed an application in the specific performance case for the issuance of a TRO and/or a writ of preliminary injunction
    to enjoin the MeTC from issuing the writ of execution/garnishment. Trial court granted Bachrach’s application. MR of PPA was
    denied. Thus, PPA filed a petition for certiorari and prohibition with the CA, which rendered the assailed decision nullifying and
    setting aside the orders of the RTC and ordering the latter to dismiss the specific performance case.

    Hence, the instant petition filed by Bachrach.

    ISSUE: Whether or not the specific performance case should be held barred by the unlawful detainer case on the ground of  res
    judicata.

    RULING: NO. There are four (4) essential conditions which must concur in order that res judicata may effectively apply,  viz: (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 or order on the merits, and (4) there must be
    between the first and second action identity of parties, identity of subject matter, and identity of causes of action." 

    The first three elements of res judicata are here extant; it is the final condition requiring an identity of parties, of subject matter and
    of causes of action, particularly the last two, i.e., subject matter and cause of action, that presents a problem.

    A cause of action, broadly defined, is an act or omission of one party in violation of the legal right of the other.  The subject matter,
    on the other hand, is the item with respect to which the controversy has arisen, or concerning which the wrong has been done, and
    it is ordinarily the right, the thing, or the contract under dispute.  In a breach of contract, the contract violated is the subject matter
    while the breach thereof by the obligor is the cause of action. The ultimate test in ascertaining the identity of causes of action is said
    to be to look into whether or not the same evidence fully supports and establishes both the present cause of action and the former
    cause of action. In the affirmative, the former judgment would be a bar; if otherwise, then that prior judgment would not serve as
    such a bar to the second. 

     The evidence needed to establish the cause of action in the unlawful detainer case would be the lease contract and the violation of
    that lease by Bachrach. In the specific performance case, what would be consequential is evidence of the alleged compromise
    agreement and its breach by PPA.

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