Progressive Development Corporation, Inc. v. Court of Appeals and Westin Seafood Market, Inc.
REITERATIONFacts
1. The Antecedents: Progressive Development Corporation, Inc. (PDC) leased a parcel of land with a commercial building to Westin Seafood Market, Inc. (Westin) for a term of over nine years. The lease agreement contained provisions allowing PDC to automatically terminate the contract and repossess the premises, including selling any remaining movable properties of Westin, in case of rental default. Westin failed to pay rentals, accumulating a significant arrearage. Consequently, PDC, invoking the lease provisions, repossessed the premises and inventoried Westin's movable properties, scheduling a public auction. 2. Procedural History: In response to PDC's repossession, Westin filed a complaint for forcible entry with damages against PDC before the Metropolitan Trial Court (MeTC). The MeTC issued a temporary restraining order enjoining the auction. Subsequently, Westin filed a separate action for damages against PDC with the Regional Trial Court (RTC), seeking moral, exemplary, actual, and compensatory damages. PDC moved to dismiss the RTC case on grounds of litis pendencia and forum shopping. The RTC initially archived the case, then later denied the motion to dismiss, admitted an amended complaint, and issued a temporary restraining order against PDC. PDC then filed a special civil action for certiorari and prohibition with the Court of Appeals (CA), arguing the RTC judge acted with grave abuse of discretion. The CA dismissed PDC's petition, finding that a motion for reconsideration was not filed and that the elements of litis pendencia were lacking because the damages claimed in the RTC were distinct from those recoverable in the MeTC forcible entry case. 3. The Petition: Progressive Development Corporation, Inc. (PDC) seeks review of the Court of Appeals' decision via a petition for certiorari under Rule 45 of the Rules of Court. PDC argues that the CA erred in finding that it failed to exhaust the remedy of a prior motion for reconsideration with the RTC, in ruling that the RTC judge did not commit grave abuse of discretion by taking cognizance of the damages action despite the pending forcible entry case, and in concluding that Westin did not engage in forum shopping because the causes of action in the two cases were not identical. PDC contends that both actions arose from the same cause of action, constituting splitting of a single cause of action and forum shopping, and that the MeTC had exclusive jurisdiction over all damages arising from the forcible entry.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari for failure to file a motion for reconsideration. Whether the Regional Trial Court judge acted with grave abuse of discretion in taking cognizance of the action for damages despite the pendency of the forcible entry case, thereby potentially splitting the cause of action. Whether the private respondent committed forum shopping by filing a separate suit for damages.
Ruling
The petition is granted. The decision of the Court of Appeals is reversed and set aside. The Regional Trial Court is directed to dismiss the action for damages, and the Metropolitan Trial Court is directed to proceed with the disposition of the forcible entry case.
Ratio Decidendi
On the procedural issue of failure to file a motion for reconsideration: The Supreme Court held that while generally a motion for reconsideration is a prerequisite to filing a petition for certiorari, this rule admits exceptions. The Court found that in this case, the issue raised by petitioner was purely legal, and any motion for reconsideration of the trial court's order would have been a pointless exercise, thus justifying the direct resort to certiorari. On the issue of litis pendencia and splitting of cause of action: The Court reiterated that under Rule 70 of the Rules of Court, all claims for damages arising from forcible entry or unlawful detainer must be filed together with the action for restoration of possession before the MeTC. Filing a separate suit for damages constitutes splitting a single cause of action, which is prohibited under Rule 2 of the Rules of Court. The Court emphasized that the act of unlawfully taking possession of the leased premises by the lessor is a single delict or wrong, giving rise to one cause of action, even if it violates multiple rights. Therefore, all reliefs, including damages, must be sought in a single complaint. On the issue of forum shopping: The Court found that private respondent committed forum shopping. By filing a separate suit for damages with the RTC while a forcible entry case involving the same cause of action was pending with the MeTC, and by failing to disclose the pendency of the MeTC case in its complaint before the RTC, private respondent engaged in forum shopping. The Court noted that the amended complaint even falsely stated that no other action was pending between the parties involving the same causes of action. This conduct trifles with the judicial process and burdens the courts.
Main Doctrine
A lessee who files a complaint for forcible entry with damages before the Metropolitan Trial Court (MeTC) cannot subsequently file a separate suit for damages before the Regional Trial Court (RTC) based on the same cause of action, as this constitutes splitting a cause of action and forum shopping. All claims for damages arising from forcible entry must be included in the initial MeTC case.