Cokaliong Shipping Lines, Inc. v. Amin
REITERATIONFacts
The Antecedents: Petitioner Cokaliong Shipping Lines, Inc. (Cokaliong) filed a Complaint for Damages against Carlos A. Go Thong Lines and Eugenio Manubag, Jr. with the RTC of Cebu (Cebu Case), alleging that a collision between their vessels, the M/V Filipinas Tandag and the M/V Our Lady of Lourdes, on April 3, 1992, was caused by the negligence of the defendants. The defendants, in their Answer with Counterclaim, denied negligence and imputed fault to Cokaliong's vessel and crew. Procedural History: On February 1, 1993, Prudential Guarantee and Assurance, Inc. (Prudential), as insurer of Go Thong Lines, filed a Complaint against Cokaliong with the RTC of Makati (Makati Case), claiming subrogation to the rights of Go Thong Lines and seeking collection of P2,420,325.59, based on the same allegations of negligence by Cokaliong's officers and crew. The Petition: Cokaliong filed a Motion to Dismiss the Makati Case on the ground of litis pendentia, which was denied by the RTC. The RTC held that the Cebu Case was for damages arising from negligence, while the Makati Case was for collection of a sum of money under subrogation. Cokaliong's Motion for Reconsideration was also denied, leading to the present petition for certiorari.
Issue(s)
Whether the pendency of Civil Case No. 11660 (Cebu Case) is a ground for the dismissal of Civil Case No. 93-319 (Makati Case) on the ground of litis pendentia, considering the identity of parties, rights asserted, and the potential for res judicata. Whether the requisites for litis pendentia are present in this case, specifically addressing the identity of parties, the identity of rights asserted and relief prayed for, and the identity such that judgment would constitute res judicata, including the effect of the counterclaim.
Ruling
The petition is GRANTED. The questioned orders dated September 1, 1993, and October 7, 1993, are SET ASIDE, and Civil Case No. 93-319, pending before Branch 135 of the Regional Trial Court of Makati, is DISMISSED.
Ratio Decidendi
On whether the pendency of the Cebu Case is a ground for dismissal based on litis pendentia: The Court held that the petition is well-taken and that the Makati Case should be dismissed on the ground of litis pendentia. For litis pendentia to be a ground for dismissal, three requisites must concur: (a) identity of parties or at least those representing the same interests; (b) identity of rights asserted and relief prayed for, founded on the same facts; and (c) the identity in the two cases should be such that the judgment in one would amount to res judicata in the other. The Court found that all these requisites were met. The Court found that while the positions of the parties were reversed, there was an identity of parties because Prudential filed the Makati Case as a subrogee of Go Thong Lines, effectively stepping into the shoes of Go Thong Lines and representing the same interests. The Court determined that the asserted rights in both cases were founded on an identical set of facts, namely, the collision between the two vessels and the determination of who was negligent. The Court concluded that the identity in both cases was such that a decision in the Cebu Case would constitute res judicata on the Makati Case, as any judgment would determine which party was at fault. On whether the requisites for litis pendentia are present: The Court further noted that Go Thong Lines had filed an Answer with Counterclaim in the Cebu Case, alleging negligence on the part of Cokaliong. Since a counterclaim partakes of the nature of a complaint, the pendency of this counterclaim, which involved identical parties and sought the same reliefs as the Makati Case, was an additional ground for dismissing the complaint filed by Go Thong Lines' insurer. The Court cited jurisprudence holding that the reversal of parties' positions does not negate the identity of parties for litis pendentia purposes. The Court reiterated its ruling in Pampanga Bus Company v. OCFEMIA that imputing negligence to each other and claiming damages based on the same incident establishes the identity of rights asserted and prayed for as based on the same facts.
Main Doctrine
The pendency of a counterclaim in a prior case involving the same parties and issues constitutes a ground for dismissal of a subsequent case filed by the subrogee of one of the parties in the prior case, based on the principle of litis pendentia.