Susana Salido v. Court of Appeals

Summary

Susana Salido held an unregistered chattel mortgage securing a debt of P252,200.00 from the Perez spouses. When the spouses filed for insolvency, Salido registered the mortgage but was denied preferred creditor status. The Court of Appeals ruled the unregistered mortgage was invalid and subsequent registration could not retroact. Salido then sought preferred status under Article 2244 of the Civil Code, filing a second petition. The Supreme Court affirmed the dismissal, applying res judicata doctrine. The Court held that while Article 2244 might support her claim, the issue was belatedly raised and constituted relitigation of the same fundamental question of preferred creditor status. The case demonstrates the finality of judgments and prohibition against piecemeal litigation of the same cause of action under different legal theories.