New Sampaguita Builders Constructions, Inc. v. Estate of Fermina Canoso
REITERATIONFacts
1. The Antecedents: Respondents initiated a civil case against petitioners to rescind a contract of sale for a parcel of land. The parties subsequently reached an amicable settlement and filed a joint motion to dismiss the case. The Regional Trial Court (RTC) granted this motion, dismissing the case. Later, respondents filed a motion to enforce the compromise agreement, alleging petitioners violated its terms. The RTC granted this motion and ordered the issuance of a writ of execution. 2. Procedural History: Petitioners moved for reconsideration of the writ of execution order, claiming their counsel was not properly notified and that they had not violated the agreement. The RTC denied this motion. Petitioners then filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. While this petition was pending, respondents filed an ex-parte manifestation with the RTC, requesting it to recall the dismissal order and approve the compromise agreement. The RTC, realizing it had not explicitly approved the agreement, set aside its previous order granting the writ of execution. Respondents then filed their own petition for certiorari with the CA, which set aside the RTC's order and reinstated the writ of execution. Petitioners' subsequent motion for reconsideration was denied, leading to the present petition. 3. The Petition: This is a petition for review under Rule 45 of the Rules of Court, challenging the CA's decision and resolution. Petitioners raise issues of forum shopping, the propriety of the RTC's October 26, 2000 order, and whether a violation of the compromise agreement occurred. The Supreme Court notes that the issue of violation is still pending before the CA in a separate case. The Court focuses on the forum shopping claim and the RTC's jurisdiction to issue the October 26, 2000 order after the matter was already elevated to the CA.
Issue(s)
Whether respondents committed forum shopping. Whether the Court of Appeals erred in annulling the October 26, 2000 order of the Regional Trial Court. Whether there was a violation of the compromise agreement to warrant the immediate issuance of the writ of execution against petitioners.
Ruling
The petition is denied. The assailed decision and resolution of the Court of Appeals are affirmed. The Regional Trial Court's October 26, 2000 order is set aside, and the May 24, 2000 order reinstating the writ of execution is upheld.
Ratio Decidendi
On the issue of forum shopping: The Court ruled that respondents did not commit forum shopping. Forum shopping involves filing multiple suits for the same cause of action to seek a favorable disposition from another court after an adverse opinion. While the issues in the two petitions before the CA (CA G.R. No. 60916 and CA G.R. No. 62672) appeared similar, a closer analysis revealed distinct issues. CA G.R. No. 60916 questioned the issuance of the writ of execution despite the dismissal order and the factual basis for enforcement, assuming the agreement was approved. CA G.R. No. 62672, however, specifically addressed whether the RTC had approved the compromise agreement in the first place, an issue that arose only after the RTC's October 26, 2000 order. The Court emphasized that forum shopping is the institution of multiple actions grounded on the same cause of action, which was not the situation here, as each party filed separate petitions against different orders. On the propriety of the October 26, 2000 Order: The Court held that the Court of Appeals correctly set aside the October 26, 2000 order. Once a matter, such as the force and effect of the May 24, 2000 order, is elevated to the Court of Appeals, the Regional Trial Court effectively loses jurisdiction to act on the same matter. The RTC cannot interfere with or preempt the appellate court's action. In this case, after the RTC judge realized a potential mistake in the May 24, 2000 order, the proper procedure would have been to make a manifestation to the CA. Instead, the RTC issued the October 26, 2000 order, attempting to correct itself without the CA's cognizance. This constituted a loss of jurisdiction, as the RTC should not have interfered with the proceedings pending before the CA. The CA's action in setting aside the RTC's order was therefore proper, as the RTC no longer had the authority to reconsider the May 24, 2000 order after it was appealed. On the violation of the compromise agreement: The Court explicitly stated that it would not pass upon this issue, as it was still pending before the Court of Appeals in CA G.R. No. 60916. The present petition for review was limited to the issues of forum shopping and the propriety of the RTC's October 26, 2000 order.
Main Doctrine
A trial court loses jurisdiction to act on a matter once it has been elevated to an appellate court, and any subsequent order issued by the trial court on the same matter is void.