Masagana Telamart, Inc. v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: This case originates from a simple ejectment suit filed by Masagana Telamart, Inc. and David S. Tiu against Rodolfo G. Merto. The City Court of Manila ruled in favor of the plaintiffs, ordering the defendant to vacate the leased premises and pay back rentals and attorney's fees. 2. Procedural History: The defendant, Rodolfo G. Merto, challenged the City Court's decision not through a standard appeal, but via a petition for certiorari to the Court of First Instance, alleging errors in evidence, factual appreciation, and due process. This petition was initially dismissed, then reinstated, leading Masagana Telamart, Inc. and Tiu to seek certiorari from the Intermediate Appellate Court (IAC), which set aside the reinstatement order. Merto's subsequent petition to the Supreme Court challenging the IAC's resolution was denied. Meanwhile, Merto filed a separate suit for annulment of the ejectment judgment, which was dismissed by the Regional Trial Court on grounds of res judicata. Merto appealed this dismissal to the IAC, which then issued a preliminary injunction restraining the execution of the ejectment judgment, the resolution now under review. 3. The Petition: Masagana Telamart, Inc. and David S. Tiu filed a petition for certiorari with the Supreme Court to set aside the resolution of the Intermediate Appellate Court dated December 28, 1984. They argue that the IAC's injunction restraining the execution of the ejectment judgment was improperly issued, contending that Merto's annulment suit was barred by res judicata and constituted a dilatory tactic to avoid the final judgment in the original ejectment case.
Issue(s)
Whether the IAC gravely abused its discretion in issuing a writ of preliminary injunction to restrain the execution of the ejectment judgment. Whether Merto's second suit for annulment of the ejectment judgment was barred by res judicata and constituted a multiplicity of suits.
Ruling
The petition is granted. The questioned resolution of the Intermediate Appellate Court is set aside, and the case where it was issued is dismissed.
Ratio Decidendi
On the issue of the IAC's abuse of discretion: The Court found the petition to be highly impressed with merit, condemning the dilatory tactics of the private respondent. The Court reiterated the principle that litigation must end and terminate sometime and somewhere, and it is essential to an effective and efficient administration of justice that once a judgment has become final, the winning party be not, through a mere subterfuge, deprived of the fruits of the verdict. Courts must guard against any scheme calculated to bring about that result and should frown upon any attempt to prolong controversies. On the issue of res judicata and multiplicity of suits: The issues and reliefs sought in the certiorari case filed in the Court of First Instance were substantially the same as those in the annulment suit filed in the Regional Trial Court. Furthermore, there was a substantial identity of parties in both cases. Consequently, when the first case (the certiorari petition in the CFI) was finally decided, the second case (the annulment suit in the RTC), aside from violating the rule on multiplicity of suits, became moot and academic and should have been dismissed.
Main Doctrine
A subsequent suit involving substantially the same issues and reliefs, parties, and causes of action as a prior decided case is barred by res judicata and constitutes a multiplicity of suits, and courts must guard against schemes to prolong litigation and deprive winning parties of the fruits of their verdict.