Catayas v. Court of Appeals
REITERATIONFacts
The Antecedents: Juan Caminos was the registered owner of several real properties. Upon his death, the administrators of his estate filed an ejectment case against several individuals, including petitioner Dorotea Catayas, who was occupying Lot No. 3928. The Municipal Trial Court in Cities (MTCC) ruled in favor of the estate, ordering the defendants to vacate the premises. The Regional Trial Court (RTC) affirmed the MTCC decision. Procedural History: Catayas filed a motion for extension of time to file a petition for review before the Court of Appeals (CA). The CA granted a 15-day extension. Subsequently, Catayas filed a second motion for extension, which the CA denied, citing Section 1, Rule 42 of the Rules of Court, which generally allows only one extension. The CA reasoned that having two counsels, the inability of one to file within the period was not a compelling reason for another extension. Catayas' motion for reconsideration was also denied. The Petition: Catayas filed a petition for certiorari before the Supreme Court, alleging grave abuse of discretion by the CA in denying her second motion for extension. She argued that the negligence of her counsel should not bind her, as she was not privy to legal proceedings.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in denying petitioner's second motion for extension of time to file a petition for review. Whether the petitioner engaged in forum shopping.
Ruling
The petition is DENIED. The Court found that the petitioner engaged in forum shopping, which is a ground for dismissal.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the second motion for extension: The Court found no grave abuse of discretion on the part of the Court of Appeals. The CA correctly applied Section 1, Rule 42 of the Rules of Court, which generally permits only one extension of time to file a petition. The CA's observation that Catayas was represented by two counsels further supported its denial, as the presence of multiple legal representatives indicated that the failure of one to meet the deadline should not necessarily prejudice the client if another counsel could have acted. The right to appeal is a statutory right that must be exercised in the manner prescribed by law, and extensions are not a matter of right but of sound judicial discretion. On the issue of forum shopping: The Court held that Catayas clearly violated the rule against forum shopping. She had previously filed a petition for review before the Supreme Court (G.R. No. 166396) questioning the same CA resolutions. This petition was filed on January 18, 2005, and subsequently denied by the Court on January 24, 2005, becoming final and executory on March 9, 2005. The filing of the present petition on February 1, 2005, while the earlier petition was still pending or had just been resolved, constituted forum shopping. Forum shopping is defined as the act of a party against whom an adverse judgment or order has been rendered in one forum, of seeking and possibly getting a favorable opinion in another forum, other than by appeal or special civil action for certiorari. It also includes the institution of two or more actions or proceedings grounded on the same cause, on the supposition that one or the other court would make a favorable disposition. The Court emphasized that forum shopping adds to the congestion of court dockets, trifles with court rules, and hampers the administration of justice.
Main Doctrine
The filing of a petition for review before the Supreme Court simultaneously with another petition involving the same parties and questioning the same resolutions issued by the Court of Appeals constitutes forum shopping, which warrants the dismissal of the case.