Philippine National Railways v. Pobre
REITERATIONFacts
The Antecedents: Spouses Victorino Cusi and Pilar Pobre filed an action for damages against the Philippine National Railways (PNR) (Civil Case No. 7948) before the Court of First Instance (CFI) of Rizal. The CFI ordered PNR to file a third-party complaint against United Housing Corporation, but PNR failed to comply. The CFI denied PNR's subsequent motion to amend its answer to include a third-party complaint, citing undue delay and the fact that plaintiffs had already presented their evidence. Procedural History: PNR filed a motion for reconsideration of the CFI's denial, which was also denied. PNR then filed a petition for mandamus and certiorari with the Supreme Court (G.R. L-27123) seeking to annul the CFI orders and compel the admission of its amended answer. This petition was dismissed by the Supreme Court. Subsequently, PNR filed a similar petition with the Court of Appeals (CA-G.R. No. 38906-R), which was also dismissed on grounds of lack of jurisdiction and prior dismissal by the Supreme Court. The Petition: PNR filed the present petition (G.R. L-27501) with the Supreme Court, raising the same issues for the third time, praying for a writ of mandamus to compel the Court of Appeals to exercise its appellate jurisdiction and resolve the merits of its petition in CA-G.R. No. 38906-R, and a writ of certiorari to declare null and void the resolutions of the Court of Appeals dated February 28, 1967, and April 6, 1967.
Issue(s)
Whether the Supreme Court should issue a writ of mandamus to compel the Court of Appeals to resolve a petition for mandamus and certiorari. Whether the resolutions of the Court of Appeals dated February 28, 1967, and April 6, 1967, are null and void due to grave abuse of discretion. Whether the Court of First Instance committed grave abuse of discretion in denying PNR's motion to amend its answer to include a third-party complaint.
Ruling
The Supreme Court denied the motion to give due course to the petition and declared its resolution of May 17, 1967, as final. The Court found that the issues raised in the present petition had already been passed upon and resolved in two prior identical petitions filed by PNR.
Ratio Decidendi
On the issue of whether the Supreme Court should issue a writ of mandamus to compel the Court of Appeals to resolve a petition for mandamus and certiorari: The Court found that the PNR's petition for mandamus and certiorari before the Court of Appeals (CA-G.R. No. 38906-R) was dismissed by the appellate court. The Supreme Court's role in the present petition (G.R. L-27501) was to review the propriety of the Court of Appeals' dismissal. However, the Court noted that the PNR was raising the same issues for the third time, having previously filed identical petitions with the Supreme Court (G.R. L-27123) and the Court of Appeals (CA-G.R. No. 38906-R). The Court reiterated its dismissal of the first petition and affirmed the Court of Appeals' dismissal of the second. On the issue of whether the resolutions of the Court of Appeals dated February 28, 1967, and April 6, 1967, are null and void due to grave abuse of discretion: The Court found no merit in PNR's contention. The Court of Appeals dismissed PNR's petition on two grounds: first, that the action pending before the Court of First Instance involved damages exceeding the appellate court's jurisdiction, meaning the writs prayed for were not in aid of its appellate jurisdiction; and second, because PNR had previously filed an identical petition with the Supreme Court which was dismissed. These grounds were deemed valid by the Supreme Court, negating any grave abuse of discretion. On the issue of whether the Court of First Instance committed grave abuse of discretion in denying PNR's motion to amend its answer to include a third-party complaint: The Supreme Court found that the CFI did not commit grave abuse of discretion. The CFI had denied the motion due to PNR's excessive delay in filing it, having been ordered to file the third-party complaint much earlier and having failed to do so despite multiple motions. The CFI correctly cited jurisprudence holding that there are limits to the time within which a party may amend its pleadings, generally before trial or hearing on the merits. Allowing the amendment at such a late stage, after the plaintiffs had already presented their evidence, would prejudice the opposing party and alter the defense significantly without giving the third party a chance to be heard.
Main Doctrine
A petition for mandamus and certiorari will be denied if the same issues have been raised and resolved in prior identical petitions before the Supreme Court and the Court of Appeals, constituting a violation of the principle against forum shopping and res judicata.