Does the res judicata doctrine apply in this case?

Finally, considerations of judicial economy do not justify application of res judicata principles in this context. Because most failures of proof like the one at issue here are inadvertent, rather than strategic or otherwise intentional, the number of retrials our conclusion permits would, no doubt, be fairly small. Moreover, a trial of a prior conviction allegation "is simple and straightforward," and "[o]ften ... involves only the presentation of a certified copy of the prior conviction along with the defendant's photograph and fingerprints. In many cases, defendants offer no evidence at all, and the outcome is relatively predictable." (Monge I, supra, 16 Cal.4th at p. 838, 66 Cal.Rptr.2d 853, 941 P.2d 1121 (lead opn. of Chin, J.).) Thus, the judicial resources saved by precluding retrials of prior conviction allegations would be minimal. Any concern about judicial economy is insufficient to overcome California's "strong interest" in protecting its citizens from recidivists. (People v. Levin, supra, 191 Ill.Dec. 72, 623 N.E.2d at p. 327.) Thus, the balance of policy interests justifies our refusal to apply either aspect of the res judicata doctrine in the present context.