Matela v. Chua Tay
REITERATIONFacts
The Antecedents: Chua Tay, a furniture manufacturer, filed an amended petition for injunction with damages against Arcadio G. Matela and others, alleging that the members of the Board of Directors of the Central Cooperative Exchange, Inc. (CCE), including Matela, solicited kickbacks during the processing of bids for a contract. Chua Tay further alleged that these directors, including Matela, engaged in acts showing grave abuse of discretion, favoritism, and detriment to government funds in awarding a contract to Carried Lumber Company. Procedural History: Matela and other respondents filed counterclaims in the injunction case, alleging damages due to the allegedly false and libelous imputations made by Chua Tay. Subsequently, Matela filed a separate action against Chua Tay for damages, alleging that the allegations in Chua Tay's amended petition were defamatory and libelous. Chua Tay filed a motion to dismiss Matela's complaint on the grounds of pendency of another action, lack of jurisdiction, and failure to state a cause of action. The trial court dismissed Matela's complaint, finding a pending action between the same parties for the same cause of action, as Matela's claim in the new complaint was substantially the same as his counterclaim in the earlier injunction case. The Petition: Matela appealed the dismissal, arguing that the motion to dismiss was not timely filed after an answer had been submitted and that the dismissal itself was improper.
Issue(s)
Whether the filing of a motion to dismiss on the ground of pendency of another action is permissible after an answer has been filed. Whether the complaint in Civil Case No. Q-4019 (Matela v. Chua Tay) states a cause of action, given the pendency of Civil Case No. 38862 (Chua Tay v. Matela, et al.) where Matela's claim was raised as a counterclaim.
Ruling
The Supreme Court affirmed the dismissal of Matela's complaint. The Court held that the ground of pendency of another action was properly raised as an affirmative defense in the answer and could be considered alongside the motion to dismiss, especially since both raised the same issue. Furthermore, the Court found that Matela's claim in his complaint was substantially the same as his counterclaim in the earlier case, constituting a splitting of a cause of action and thus barred by lis pendens.
Ratio Decidendi
On the propriety of the motion to dismiss after filing an answer: The Court ruled that the dismissal was proper. While generally, a motion to dismiss on the ground of pendency of another action is a plea in abatement that is deemed waived if not filed before an answer, the rules allow for such a defense to be raised in the answer itself as an affirmative defense. In this case, the defendant Chua Tay raised the pendency of another action both in his motion to dismiss and in his affirmative defenses in the answer. The lower court correctly considered these grounds, especially since the preliminary hearing covered both the motion to dismiss and the affirmative defenses. This procedure is permissible under Rule 8, Section 5 of the Rules of Court, which allows for the hearing of affirmative defenses. On the existence of a pending action and splitting of cause of action: The Court found that there was indeed a pending action between the same parties for the same cause of action. The claim of Matela against Chua Tay in the present case (Civil Case No. Q-4019) was a mere reproduction and substantially the same as the allegations raised by Matela in his counterclaim in the earlier case (Civil Case No. 38862). A counterclaim partakes of the nature of a complaint or a cause of action against the plaintiff. To interpose a cause of action in a counterclaim and then invoke it again in a separate complaint against the same party would be considered splitting a cause of action, which is not sanctioned by the rules. The Court emphasized the requisites for the pendency of another suit to be a ground for dismissal: identity of parties, identity of rights asserted and relief prayed for, and the relief being founded on the same facts, such that a judgment in one would be res judicata in the other. These requisites were met in this case.
Main Doctrine
A cause of action asserted in a counterclaim in one case cannot be subsequently filed as a formal complaint in another case between the same parties, as this constitutes splitting a cause of action and is barred by the principle of lis pendens.