St. Catherine Realty v. Pineda
REITERATIONFacts
The Antecedents: Ferdinand Y. Pineda and Dolores S. Lacuata (respondents) purchased parcels of land from George Lizares in 1991. Pineda bought a portion of Lot No. 2012 (TCT No. 3533), and Lacuata bought Lot No. 2013 (TCT No. 3531). At the time of sale, the properties were still registered under Encarnacion Lizares, prompting respondents to record adverse claims. Subsequently, the lots were placed under the land reform program and distributed to agricultural tenants via emancipation patents in 1993. Lizares initiated actions to annul the inclusion of his lands in the program and later sought the cancellation of the issued emancipation patents, but these were dismissed by the PARAD and affirmed by the DARAB. Procedural History: Respondents filed a specific performance action (Civil Case No. 10265) in 1994 against Lizares for the surrender and cancellation of titles and issuance of new ones. Their counsel, Atty. Ernesto Pineda, who also purchased land from Lizares and claimed attorney's liens, filed a notice of lis pendens. The recipients of the emancipation patents intervened and moved to dismiss, leading the RTC Branch 45 to dismiss Civil Case No. 10265 without prejudice in 1997, deeming the prayer for TCT cancellation moot and the sale to respondents void. The Court of Appeals dismissed the subsequent appeal, and this Court denied the petition for review (G.R. No. 143492) due to a procedural defect. Meanwhile, Lizares's appeal from the DARAB decision was also dismissed by the Court of Appeals, and his subsequent petition for review (G.R. No. 148777) was pending before this Court. Respondents then filed another action (Civil Case No. 12194) in 2001 for annulment of titles and damages against St. Catherine Realty Corporation and Land King Realty Development Corporation (petitioners), alleging they were subsequent buyers in bad faith and that their adverse claims were not carried over to new titles. The RTC Branch 44 initially dismissed this case but later set aside the dismissal. After the case was re-raffled, RTC Branch 47 denied petitioners' motion for reconsideration. Petitioners then filed a petition for certiorari before the Court of Appeals. The Petition: The Court of Appeals, in its 29 December 2005 Decision and 14 February 2006 Resolution, dismissed petitioners' petition for certiorari, ruling that while the certification against forum shopping did not explicitly mention prior cases, the complaint itself referred to Civil Case No. 10265. The appellate court also found no litis pendencia with the DARAB cases due to lack of identity of parties and with Civil Case No. 10265 due to different subject matters. Petitioners filed a petition for review under Rule 45 of the Rules of Civil Procedure before this Court, arguing that respondents were guilty of forum shopping by filing Civil Case No. 12194 while G.R. No. 143492 was still pending, and that there was substantial identity of parties, rights, and reliefs between Civil Case No. 10265 and Civil Case No. 12194, despite the Court of Appeals' findings.
Issue(s)
Whether Respondents are guilty of forum shopping for filing Civil Case No. 12194 for annulment of titles while G.R. No. 143492 (originating from Civil Case No. 10265) was still pending before the Supreme Court.
Ruling
The Supreme Court granted the petition, set aside the decisions of the Court of Appeals and the orders of the RTCs, and reinstated the order of RTC Branch 44 dismissing the complaint. The Court found that respondents were guilty of forum shopping.
Ratio Decidendi
On Issue 1: Respondents are guilty of forum shopping because all three requisites are present. First, there is an identity of interests between the parties; although Petitioners were not parties in the first case, they are the successors-in-interest of Lizares as the subsequent buyers of the lots originally covered by TCT Nos. 3531 and 3533. Applying the ruling in T'boli Agro-Ind'l. Dev't., Inc. v. Atty. Solilapsi, litis pendencia does not require literal identity of parties, only identity of interests. Second, there is an identity of rights and reliefs because Respondents were claiming the exact same lots purchased from Lizares in both cases. Third, any judgment rendered in G.R. No. 143492 regarding the validity of the sale and the effect of the land reform program would invariably constitute res judicata in the subsequent annulment case. Furthermore, the Court emphasized that Respondents failed to apprise the RTC in the second case about the specific status of the first case—namely its pendency before the Supreme Court. The mere enumeration of the transfer of titles in the body of the complaint does not satisfy the mandatory requirement to state the status of the pending action in the Certification Against Forum Shopping.
Main Doctrine
Forum shopping exists when there is an institution of two or more suits in different courts, either simultaneously or successively, in order to ask the courts to rule on the same or related causes or to grant the same or substantially the same reliefs. The requisites are: (1) identity of parties, or at least such parties who represent the same interests in both actions; (2) identity of the rights asserted and the relief prayed for, the relief being founded on the same facts; and (3) identity of the two preceding particulars such that any judgment rendered in the pending case, regardless of which party is successful, would amount to res judicata in the other. Failure to disclose the pendency of a related case in the certification against forum shopping constitutes forum shopping.