Doctrine of "judicial economy"

Judicial economy, or the goal to have cases prosecuted with the least cost to the parties, requires that unnecessary or frivolous reviews of orders by the trial court, which facilitate the resolution of the main merits of the case, be reviewed together with the main merits of the case. After all, it would be more efficient for an appellate court to review a case in its entire context when the case is finally disposed. (794 Phil. 97, 2016)

In our age, where courts are harassed by crowded dockets and complaints against slow foot justice, frequent technical reliance on the preclusive breadth of res judicata is understandable. The importance of judicial economy and avoidance of repetitive suits are strong norms in a society in need of swift justice. Be that as it may, there should not be a mechanical and uncaring reliance on res judicata where more important societal values deserve protection. (G.R. No. 100156. June 27, 1994)For the above reading, the Supreme Court of the Philippines held in Suarez v. Court of Appeals:

"Assuming in gratia argumenti that the prior judgment of dismissal with prejudice was validly rendered within the lawful discretion of the court and could be considered as an adjudication on the merits, nonetheless, the principle of res judicata should be disregarded if its application would involve the sacrifice of justice to technicality (Republic v. De los Angeles, No. L-30240, March 25, 1988, 159 SRA 264). The application of the said principle, under the particular facts obtaining, would amount to denial of justice and/or bar to a vindication of a legitimate grievance (Ronquillo v. Marasigan, No. L-11621, May 31, 1962, 5 SCRA 304). It is worth stating here that the controversy in the instant case is not just an ordinary suit between parties over a trivial matter but a litigation initiated by then natural mother over the welfare and custody of her child, in which the State has a paramount interest. The fundamental policy of the State as embodied in the Constitution in promoting and protecting the welfare of children shall not be disregarded by the courts by mere technicality in resolving disputes which involve the family and the youth."

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