Republic v. Corpin
REITERATIONFacts
The Antecedents: The Republic of the Philippines, through the Provincial Fiscal of Leyte and upon the relation of Jose Napalit, filed a complaint for quo warranto seeking to exclude Iñigo Pablico Corpin from the office of Municipal Mayor of Biliran, Leyte, on the ground that he was not a Filipino citizen and thus unlawfully holding the position. Procedural History: The defendant filed a motion to dismiss, arguing that Jose Napalit, a defeated candidate, had previously filed a similar quo warranto petition against him, which was decided in the defendant's favor by the Court of First Instance and was then pending appeal before the Court of Appeals. The Provincial Fiscal opposed the dismissal, contending that the Republic was not a party to the first case. The trial court initially allowed the withdrawal of the motion to dismiss but reserved the right to oppose the complaint's admission. Subsequently, the defendant filed an opposition based on the same grounds. On September 17, 1956, the court denied permission to commence the action, citing the lapse of the one-week period after proclamation and the pendency of the prior quo warranto case. A motion for reconsideration was denied, leading to the present appeal by the provincial fiscal. The Appeal: The Republic of the Philippines appealed the order denying permission to file the quo warranto action. The appellant argued that the lower court erred in requiring permission to file the action, in holding that the prior quo warranto case could be pleaded in abatement under the principle of res judicata, and in not giving due course to the present action.
Issue(s)
Whether the lower court erred in holding that permission was required to file the quo warranto petition. Whether the lower court erred in holding that the prior quo warranto case could be pleaded in abatement of the present action on the ground of res judicata. Whether the lower court erred in not giving due course to the present action for quo warranto.
Ruling
The Supreme Court affirmed the order of the Court of First Instance denying permission to commence the quo warranto action. No costs were awarded.
Ratio Decidendi
On Issue 1: The Supreme Court found that the Republic of the Philippines was not in a position to charge the trial court with error for requiring permission to file the quo warranto action. This is because the Republic's own petition invoked Section 4 of Rule 68 of the Rules of Court, which explicitly requires the permission of the court. The appellant had induced and persuaded the lower court to take the action it now challenged as erroneous. Therefore, the appellant could not fault the trial court for following the provision it itself invoked. On Issue 2: The Court held that the pendency of another quo warranto case involving the same subject matter and parties, which was decided by the trial court and was pending appeal, could be pleaded in abatement of the present action. The reasoning was that a final decision in the pending appeal, whether by the Court of Appeals or by the Supreme Court, would definitively resolve the issues involved in the present case and serve as res judicata. The Court noted that while the Government was not a party in the first case, the action was brought by a private individual under a law designed to test the right to hold public office, and the Government's interest, though significant, did not necessitate a duplicative action when an adequate remedy was already in progress. On Issue 3: The Court affirmed the denial of due course to the present action. It reasoned that the trial court should be accorded discretion to grant or withhold permission to file an action under Section 4 of Rule 68, especially when the suit is brought upon the relation of the same party who initiated a prior, similar proceeding. The Court cited legal authorities indicating that the granting or refusing of leave to institute a quo warranto proceeding rests largely in the discretion of the court, which should consider various circumstances, including the pendency of prior actions involving the same questions. Given that a prior case was already on appeal and would settle the same issue, the trial court's denial of permission was a proper exercise of its discretion.
Main Doctrine
The Supreme Court reiterated that the trial court possesses broad discretion in granting or denying permission to commence a quo warranto action under Section 4 of Rule 68 of the Rules of Court. This discretion is particularly significant when the proposed action is filed at the instance of the same relator who initiated a prior, similar quo warranto proceeding concerning the same respondent and issue. The pendency of an appeal in the Court of Appeals for the first case, which would definitively resolve the issues, justifies the denial of permission for the second action on grounds of judicial economy and the principle of res judicata.