REMEDIAL LAW | Riviera Golf Club v. CCA G.R. No. 173783, June 17 2015

Riviera Golf Club v. CCA 

G.R. No. 173783, June 17 2015


FACTS Riviera Golf Club entered into a Management Agreement with CCA Holdings to manage and operate the golf club. Riviera Golf defaulted on payments and terminated the agreement prematurely. CCA Holdings filed two separate lawsuits against Riviera Golf: Civil Case 01-611 for unpaid fees and reimbursement claims, Civil Case 03-399 for damages due to premature termination of the agreement. Riviera Golf argued that the second case was barred by res judicata and splitting a single cause of action. Whether the second complaint was barred by res judicata and splitting a single cause of action.


RULING Yes. Res judicata requires the concurrence of the following requisites: (1) the former judgment must be final; (2) it must have been rendered by a court having jurisdiction of the subject matter and the parties; (3) it must be a judgment on the merits; and (4) there must be, between the first and second actions (a) identity of parties, (b) identity of subject matter, and (c) identity of causes of action.


Here, The Court found that the two cases involved the same parties, subject matter, and cause of action. The Court held that the claims for unpaid fees and damages arose from the same breach of the Management Agreement and should have been included in a single complaint. The Supreme Court rejected CCA Holdings' argument based on the non-waiver clause in the Compromise Agreement, finding it to be contrary to public policy. The Supreme Court ruled that the second complaint was barred by res judicata and splitting a single cause of action. The case was remanded to the trial court for further proceedings.







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