Lamis Ents. v. Silapan
REITERATIONFacts
1. The Antecedents: The underlying dispute involves a Komatsu Bulldozer delivered by Santiago Maningo to Neville Y. Lamis Ents. under a Memorandum Agreement. Maningo initiated Civil Case No. 1395 in the Court of First Instance of Davao, seeking, among other things, the payment of the bulldozer's value from Neville Y. Lamis Ents. The latter moved to dismiss, citing multiplicity of suits and improper venue, but this motion was denied. 2. Procedural History: This Court previously granted a petition for certiorari in G.R. No. 57250, ordering the dismissal of Civil Case No. 1395. The Court found that Civil Case No. 1395 was a duplication of Civil Case No. 35199, previously filed by Neville Y. Lamis Ents. against Santiago Maningo in the Court of First Instance of Rizal. The Court determined that Maningo's claim for the purchase price of the bulldozer should have been raised in Civil Case No. 35199. Subsequently, in December 1981, Maningo filed Civil Case No. 147 in the Court of First Instance of Davao at Tagum, initially for foreclosure of chattel mortgage, but later amended to be for replevin, damages, and attorney's fees. The court a quo granted the application for replevin, ordering the seizure of the bulldozer, reasoning that the issue was possession, not price. 3. The Petition: Neville Y. Lamis Ents. filed the instant petition, arguing that Civil Case No. 147 is duplicitous and disregards this Court's prior decision in G.R. No. 57250. They seek an order to dismiss Civil Case No. 147. The Court found the petition meritorious, concluding that the private respondent was engaged in harassment by filing successive suits and that while the claim for the purchase price was barred, litigation concerning possession was also barred by the previous decision.
Issue(s)
Whether Civil Case No. 147, filed by respondent Maningo, should be dismissed for being duplicitous and in disregard of the Supreme Court's prior decision in G.R. No. 57250. Whether the respondent judge committed a grave abuse of discretion in granting the application for replevin in Civil Case No. 147.
Ruling
The petition is granted. The respondent judge is ordered to dismiss Civil Case No. 147. Private respondent shall pay treble costs.
Ratio Decidendi
On the issue of dismissal of Civil Case No. 147: The Supreme Court found the petition impressed with merit, stating that it is obvious the private respondent is embarked on a campaign of harassment by filing suit after suit against the petitioner. While it is true that the private respondent's claim for the purchase price of the Komatsu tractor was barred in Civil Case No. 35199 and in any suit for that matter, the Court clarified that its pronouncement in G.R. No. 57250 did not prevent the Rizal Court of First Instance from deciding the question of possession in respect to the tractor. Therefore, litigation in any other case concerning said possession is not only unnecessary and improper but is also barred by the Court's decision in G.R. No. 57250. The filing of Civil Case No. 147, which sought replevin (possession) of the unit, was thus deemed barred by the prior decision and constituted harassment. On the issue of grave abuse of discretion: Although not explicitly stated as a separate issue, the Court's order to dismiss Civil Case No. 147 implicitly resolves that the respondent judge committed a grave abuse of discretion in granting the replevin order. The Court's reasoning that the issue of possession was already barred by the previous decision in G.R. No. 57250 indicates that the judge should not have proceeded with the case, especially when it was filed in disregard of a Supreme Court mandate. The Court's finding of harassment further supports the conclusion that the judge's action was improper.
Main Doctrine
Filing successive suits that are essentially the same, particularly when a prior suit has already been dismissed by the Supreme Court on grounds of multiplicity of suits and res judicata, constitutes harassment and disregard of the Court's pronouncements, warranting the dismissal of subsequent cases.