Gatmaytan v. Court of Appeals
REITERATIONFacts
The Antecedents: Metropolitan Bank & Trust Company (Metrobank) filed an ejectment suit (Civil Case No. 32033) against CIAGLO (Caparas Ilagan Alcantara & Gatmaytan Law Office) for failure to pay rentals and electric bills amounting to P76,224.99. CIAGLO was a sub-lessee of a lessee, Canlubang Automotive Resources Corporation (CARCO), occupying space in a building owned by Fortune Motors, Inc., whose successor-in-interest was Metrobank. Procedural History: Augusto Gatmaytan, a partner of CIAGLO, singly or jointly with his law firm, initiated nine (9) separate judicial remedies, primarily aimed at impugning the Metropolitan Trial Court's (MTC) jurisdiction over the ejectment suit and causing its indefinite delay. These included actions for declaratory relief, prohibition, damages, petitions for certiorari, and appeals, filed before the Regional Trial Court (RTC) and the Court of Appeals (CA), and subsequently before the Supreme Court. These remedies were consistently dismissed by the lower courts and this Court on grounds of lack of jurisdiction, improper remedy, res judicata, and forum shopping. The Petition: Gatmaytan filed a petition for review on certiorari before the Supreme Court (G.R. No. 123332) to reverse the adverse dispositions of the Court of Appeals, raising issues concerning the cause of action for ejectment, the necessity of joining indispensable parties, the nature of the action as plenary or ejectment, the effect of prior decisions on jurisdiction and res judicata, and the purpose of remanding the case. This petition was dismissed by the Supreme Court for being filed out of time, barred by res judicata, and unsubstantial. The Court also ordered Gatmaytan to show cause why he should not be held liable for forum shopping.
Issue(s)
Whether Atty. Augusto Gatmaytan is guilty of forum shopping. Whether Atty. Augusto Gatmaytan should be held liable for contempt of court. Whether Atty. Augusto Gatmaytan should be suspended from the practice of law.
Ruling
The Supreme Court found Atty. Augusto Gatmaytan guilty of contempt of court and imposed a fine of P5,000.00, with subsidiary imprisonment of fifteen (15) days in case of default. He was also suspended from the practice of law for a period of six (6) months.
Ratio Decidendi
On the issue of forum shopping: The Court found Atty. Gatmaytan guilty of forum shopping, defining it as "the institution of two (2) or more actions or proceedings grounded on the same cause on the supposition that one or the other court would make a favorable disposition" or "the act of a party against whom an adverse judgment has been rendered in one forum, of seeking another (and possibly favorable) opinion in another forum other than by appeal or the special civil action of certiorari." The facts plainly demonstrated his guilt, as he repeatedly resorted to multiple judicial remedies to challenge the MTC's jurisdiction over the ejectment suit, thereby causing indefinite delay. His justification that these remedies were "forced or duty moves" compelled by circumstances and in adherence to rules was found unacceptable. The Court emphasized that while the Rules of Court make available several remedies, a party cannot resort to them simultaneously or at pleasure, as there is a sequence and hierarchical order that must be observed. Impatience with the judicial process or a strong belief in one's cause does not justify short-cuts or playing fast and loose with the rules. The Court noted that this was the ninth time Gatmaytan had embarked on this enterprise after being rebuffed multiple times by the Court of Appeals and the Supreme Court on the same fundamental issue. He had frustrated final and executory dispositions and unwarrantedly imposed on the time and patience of the courts. On the issue of contempt of court: The Court declared Atty. Gatmaytan guilty of contempt of court for his persistent and unjustified resort to multiple legal remedies, which constituted an abuse of court processes and an impediment to the administration of justice. The Court reiterated the observations of the Court of Appeals that Gatmaytan misused technicalities and remedies to prolong a simple ejectment case, frustrating the equitable remedy provided by summary proceedings to the prejudice of the respondent and the courts. The Court stressed that lawyers should not take advantage of endless channels in the legal system to delay proceedings. His actions were characterized as having been done "for years, with evident premeditation." On the issue of suspension from the practice of law: In accordance with Rule 71 of the Rules of Court, as amended, the Court ordered the suspension of Atty. Gatmaytan from the practice of law for a period of six (6) months, effective from the finality of the judgment. This sanction was imposed as a consequence of his proven guilt of forum shopping and contempt of court, reflecting the Court's stance against lawyers who abuse legal processes and impede the administration of justice. The Court directed that a copy of the decision be entered into his record.
Main Doctrine
Atty. Augusto Gatmaytan was found guilty of contempt of court for forum shopping and suspended from the practice of law for six (6) months due to his repeated and unjustified resort to multiple judicial remedies to delay an ejectment suit, thereby frustrating final and executory dispositions and imposing on the time and patience of the courts.