Does res judicata apply in divorce cases?

A converse situation existed in Adamson v. Adamson (1962) 209 Cal.App.2d 492, 26 Cal.Rptr. 236 where the plaintiff wife alleged in a [91 Cal.App.3d 284] divorce complaint there were no children who were the issue of the marriage. The wife testified at a default hearing the marriage produced no children, and the court so found in its decree. In a subsequent proceeding for modification, the wife alleged that in fact one child was born before the filing of the dissolution action and another afterward. The husband asserted the issue of paternity was res judicata and the wife was seeking to relitigate the matter of paternity which had been determined, being the subject of a final judgment. There was no contention of extrinsic fraud. The court held the dissolution decree was binding on the husband and wife but not upon the children, saying there was no mutuality in the application of res judicata. So far as the children's rights are concerned, "It is to be kept in mind, however, that the children involved here are not foreclosed from instituting an action to have the husband declared to be their father and for an order for support and maintenance. In other words, the doctrine of res judicata cannot be invoked in this case by the husband against the children, even though the children can under the circumstances invoke the doctrine against him." (Adamson v. Adamson, supra, at p. 501, 26 Cal.Rptr. at p. 242.)