Quinsay v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner and private respondent were married and accumulated significant conjugal assets. After separating in fact, private respondent filed a petition for declaration of nullity of marriage. The trial court granted a 6-month cooling-off period and ordered the parties to agree on the dissolution of their conjugal regime. Pursuant to this, they entered into an "Agreement for the Dissolution of the Conjugal Partnership and Separation of Property," which was approved by the trial court. Procedural History: Petitioner later filed an omnibus motion to amend the agreement, alleging fraudulent concealment of conjugal properties by private respondent. Subsequently, petitioner filed a petition with the Court of Appeals (CA) for annulment of the trial court's order approving the agreement, citing fraudulent concealment and misrepresentation of asset values. The CA dismissed this petition on the ground of forum-shopping. Petitioner's subsequent motions with the CA were also denied. The Petition: The present petition seeks to determine whether the assailed CA decision is in accordance with law and evidence.
Issue(s)
Whether the petitioner committed forum-shopping. Whether there was extrinsic fraud in the execution of the compromise agreement.
Ruling
The petition is denied for lack of merit. The Court of Appeals correctly dismissed the petition on the ground of forum-shopping.
Ratio Decidendi
On the issue of forum-shopping: The Court found that petitioner committed forum-shopping. She filed a motion to amend the agreement before the trial court while simultaneously filing a petition with the Court of Appeals for the annulment of the trial court's order approving the same agreement. Both actions pertained to the same subject matter: the amendment of the compromise agreement to include allegedly concealed properties and to correct their valuations. The CA case was filed during the pendency of her motion before the trial court, which had not yet been resolved. The Court reiterated that forum-shopping occurs not only when a final judgment in one case would amount to res judicata in another, but also when the elements of litis pendentia are present. The filing of multiple suits involving the same parties for the same cause of action, aiming for a favorable judgment, constitutes forum-shopping. The Court found that all three elements of litis pendentia were present: identity of parties, identity of rights asserted and relief prayed for founded on the same facts, and the potential for res judicata between the two cases. Therefore, the CA's dismissal on the ground of forum-shopping was proper. On the issue of extrinsic fraud: The Court noted that the alleged extrinsic fraud, involving the concealment of the true worth of the family business, constitutes a factual matter. It is a well-settled principle that the Supreme Court is not a trier of facts. Such factual issues must be properly ascertained in a proceeding where evidence is duly admitted and determined in the first level of judicial proceedings. The Court cannot make a definitive finding on these matters due to insufficient evidence on record. Furthermore, resolving the issue of concealed properties would preempt the motion pending before the trial court, rendering that proceeding moot and academic.
Main Doctrine
The filing of multiple suits involving the same parties for the same cause of action, either simultaneously or successively, for the purpose of obtaining a favorable judgment amounts to forum-shopping. Litis pendentia exists when there is identity of parties, identity of rights asserted and relief prayed for, and identity of the two preceding particulars in the two cases such that any judgment would amount to res judicata.