Municipality of Taguig v. Barangay Hagonoy
REITERATIONFacts
The Antecedents: The Municipality of Taguig, its then Mayor Ricardo Papa, Jr., and Chief of the General Service Office, Roberto Santos, were in dispute with Barangay Hagonoy over the ownership and possession of the Hagonoy Multi-Purpose Hall. Barangay Hagonoy initiated legal action to prevent the Municipality from taking control of the hall. Procedural History: Barangay Hagonoy filed a complaint for damages with a prayer for injunctive relief before the Regional Trial Court (RTC) of Pasig, which issued a Temporary Restraining Order (TRO) and later extended it. The petitioners then filed a petition for certiorari and prohibition with the Court of Appeals (CA) seeking to annul the RTC's orders. While this first petition was pending, the petitioners filed a second, similar petition with the same CA, assailing a subsequent order from the RTC granting a preliminary injunction. The CA, finding this to be forum shopping, dismissed the second petition. Subsequently, the first petition was withdrawn, but the CA also noted the forum shopping in its resolution dismissing the second petition. The Petition: The petitioners seek review on certiorari of the Court of Appeals' resolutions that dismissed their second petition for certiorari and prohibition due to forum shopping and denied their motion for reconsideration. They argue that no forum shopping occurred because the two petitions assailed different orders, involved distinct issues, and were filed sequentially, with a motion to withdraw the first petition preceding the filing of the second. They contend that the CA should have consolidated the petitions rather than dismissing them.
Issue(s)
Whether the petitioners committed forum shopping. Whether the CA erred in dismissing the second petition on the ground of forum shopping.
Ruling
The petition is denied. The Resolutions dated February 2, 2000, and March 20, 2000, of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of whether the petitioners committed forum shopping: The Court held that forum shopping exists when a party institutes two or more actions or proceedings grounded on the same cause, on the gamble that one or the other court would make a favorable disposition. The true test is the vexation caused to the courts and parties-litigants by a party who asks different courts and/or administrative agencies to rule on the same or related causes and/or grant the same or substantially the same reliefs, in the process creating the possibility of conflicting decisions. In this case, although the petitioners assailed two different orders of the trial court, the reliefs sought in both petitions were the same: to prevent the respondent judge from enjoining petitioners from taking over, control, and possession of the Hagonoy Multi-Purpose Hall and from further proceeding with Civil Case No. 67720. The objective and cause of action were substantially the same, thus constituting forum shopping. On the issue of whether the CA erred in dismissing the second petition on the ground of forum shopping: The Court emphasized that the filing of two apparently different actions with the same objective constitutes forum shopping, citing Danville Maritime, Inc. vs. Commission on Audit. The Court further noted that the CA Fourteenth Division had already lifted its cease and desist order and ordered the RTC to proceed, indicating a preliminary finding against petitioners' claim of possession. Filing a second petition with another division of the CA was an attempt to improve their chances of obtaining a favorable injunction, which is a clear act of forum shopping. The Court reiterated that the rule against forum shopping applies equally to multiple petitions in the same tribunal or agency, even if different divisions are involved, as it constitutes approaching two different fora within the same court to increase chances of a favorable decision. The Court rejected the argument that there was no forum shopping because both petitions were filed in the CA, stating that the involvement of different divisions constitutes the filing in different fora. The Court also found no merit in the petitioners' claim of good faith, distinguishing the case from Executive Secretary vs. Gordon by highlighting that in the present case, the CA had already taken action on the first petition, and the second petition was filed to circumvent the law and improve chances of success. The Court stressed that forum shopping is contumacious and an act of malpractice, penalized by summary dismissal of the actions filed, as mandated by Supreme Court rules and circulars.
Main Doctrine
The filing of multiple petitions involving the same essential facts and circumstances in different divisions of the same tribunal or agency constitutes forum shopping and is punishable by summary dismissal of the actions filed.