Sps. Enriqueta Rasdas v. Jaime Estenor

Summary

Supreme Court affirmed dismissal of petitioners' complaint for just compensation, ruling it was barred by res judicata under the 'conclusiveness of judgment' doctrine. Petitioners, who had lost a previous ownership case where the Court of Appeals found their possession was by tolerance since 1965, filed a new case claiming compensation as builders in good faith for structures built in 1989-1990. The Court held that since the previous judgment established petitioners knew they weren't owners since 1965, they were builders in bad faith when they constructed the structures. Under Article 448 of the Civil Code, builders in bad faith forfeit their improvements without right to indemnity. The decision reinforces that once a factual issue is conclusively determined in a final judgment, it cannot be relitigated in subsequent cases between the same parties, even with different causes of action.