La Campana v. See
REITERATIONFacts
The Antecedents: Petitioner La Campana Development Corporation leased several warehouse and open spaces within its compound to the respondents. The lease agreements were periodically renegotiated. In 1997, the Development Bank of the Philippines (DBP) informed the respondents that it had acquired ownership of the compound, leading to the DBP taking possession. Consequently, the respondents began paying rent to the DBP, including arrears. Procedural History: On April 28, 1999, La Campana filed an ejectment suit against the respondents with the Metropolitan Trial Court (MeTC), which ruled in favor of La Campana on October 12, 1999, ordering the respondents to pay back rentals and vacate. Subsequently, the respondents filed a manifestation with the MeTC alleging extrinsic fraud and seeking modification of the decision. Before the MeTC could act, the respondents filed a petition with the Regional Trial Court (RTC) for annulment of the MeTC's decision, nullification of lease contracts, and damages, alleging extrinsic fraud and grave abuse of discretion. The RTC denied La Campana's motion to dismiss and issued a temporary restraining order, later a preliminary injunction. La Campana then filed a special civil action for certiorari with the Court of Appeals (CA) challenging the RTC's denial of its motion to dismiss. The CA dismissed La Campana's petition for lack of merit. The Petition: La Campana Development Corporation filed this petition for review on certiorari under Rule 45 of the Rules of Court, seeking to overturn the Court of Appeals' decision that dismissed its petition for certiorari. The core issue presented to the Supreme Court is whether the respondents engaged in forum shopping by filing multiple actions and motions with different courts (MeTC and RTC) concerning the same underlying dispute and seeking similar reliefs, thereby potentially leading to conflicting rulings. La Campana argues that the respondents' actions constituted forum shopping, while also asserting that its own resort to a petition for certiorari with the CA was warranted due to the RTC's alleged grave abuse of discretion.
Issue(s)
Whether respondents committed forum shopping. Whether the RTC committed grave abuse of discretion amounting to lack of jurisdiction in denying petitioner's motion to dismiss.
Ruling
The petition is dismissed. The Court ruled that respondents committed forum shopping by filing essentially the same pleadings with two different courts. However, the Court found that the RTC's denial of petitioner's motion to dismiss was an error of judgment, not an error of jurisdiction or grave abuse of discretion, making the resort to certiorari under Rule 65 unwarranted.
Ratio Decidendi
On the issue of forum shopping: The Court held that respondents committed forum shopping. Forum shopping is defined as the practice of litigants resorting to two different fora for the purpose of obtaining the same relief, thereby increasing their chances of obtaining a favorable judgment and creating the possibility of conflicting decisions. The Court found that the parties in the MeTC and RTC cases were identical, the allegations of facts giving rise to respondents' rights, such as extrinsic fraud and lack of jurisdiction, were essentially the same, and the reliefs prayed for were also similar. The Court emphasized that the prohibition against forum shopping seeks to avert the evil of vexing courts and parties-litigants with multiple actions and the possibility of conflicting rulings on the same issues. Respondents should not have filed essentially the same documents with two different courts if they wanted to avoid this problem. On the issue of grave abuse of discretion by the RTC: The Court ruled that petitioner's resort to certiorari under Rule 65 was unwarranted. The RTC's denial of petitioner's motion to dismiss was, at worst, an error in judgment and not an error of jurisdiction or grave abuse of discretion tantamount to lack or excess of jurisdiction. An error of judgment is correctable by appeal, while an error of jurisdiction involves acting without or in excess of jurisdiction or with grave abuse of discretion. Certiorari is not available to correct errors of procedure or mistakes in a judge's findings and conclusions of law and fact. Furthermore, the denial of a motion to dismiss is an interlocutory order, which cannot be questioned by certiorari until a final judgment or order is rendered. The proper remedy against such an order is to file an answer and interpose the objections as affirmative defenses, unless there are extraordinary circumstances evincing a patent disregard of justice and fair play.
Main Doctrine
Filing the same or substantially the same pleadings or motions with two different courts, seeking the same or substantially the same relief, constitutes forum shopping, which is prohibited. Resort to a special civil action for certiorari under Rule 65 is unwarranted to correct an error of judgment, which is an interlocutory order, and not an error of jurisdiction or grave abuse of discretion amounting to lack thereof.