Arania v. Sangalang
REVERSALFacts
The Antecedents: Petitioners, claiming to be lawful tenant-tillers of several agricultural landholdings since time immemorial, filed an action for recovery of possession. They presented Certificates of Land Transfer (CLTs) and certifications from the Barangay Agrarian Reform Committee (BARC) Chairman as proof of their claim. They alleged that the deceased Magdalena Sangalang, through coercion and intimidation, forced them to leave their landholdings in 1987. The respondents countered that the petitioners were not lawful tenants and that the BARC certification was falsified as the committee was organized after the alleged harassment. Procedural History: The Provincial Agrarian Reform Adjudication Board (PARAD) ruled in favor of the petitioners, ordering the respondents to relinquish possession and declaring the petitioners as lawful farmer beneficiaries. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed this decision. The respondents then filed a petition for review with the Court of Appeals (CA) Seventh Division, which dismissed the petition and affirmed the DARAB decision. Subsequently, the respondents filed a separate petition for certiorari with the CA Special Fifteenth Division, assailing a writ of execution pending appeal and challenging the jurisdiction of the PARAD and DARAB. This petition was granted, nullifying the PARAD and DARAB decisions. The petitioners' attempt to appeal the CA's certiorari decision to the Supreme Court was denied due to a procedural defect. The petitioners then filed the present petition for annulment of judgment before the Supreme Court. The Petition: The petitioners seek the annulment of the Court of Appeals' decision in the certiorari case (CA-G.R. SP No. 64164), arguing that it conflicts with the CA's earlier decision in the petition for review (CA-G.R. SP No. 57360) and that the CA Special Fifteenth Division committed a palpable error by taking cognizance of the certiorari petition. They contend that they have a favorable judgment from the PARAD, DARAB, and the CA Seventh Division, but cannot enforce it due to the conflicting CA Special Fifteenth Division judgment. The Supreme Court, while noting the procedural impropriety of the annulment petition, reviewed the case and found the respondents guilty of forum shopping by filing both a petition for review and a petition for certiorari, creating conflicting decisions. The Court nullified the CA's certiorari decision and ordered the execution of the CA Seventh Division's decision.
Issue(s)
Whether the Court of Appeals' decision in the petition for certiorari may be nullified and set aside. Whether the respondents engaged in willful and deliberate forum shopping.
Ruling
The petition is GRANTED. The Decision dated 30 October 2001 of the Court of Appeals in CA-G.R. SP No. 64164 and the Resolution of the Supreme Court in G.R. No. 150695, as well as all orders and issuances emanating therefrom, are NULLIFIED and SET ASIDE. The respondents are declared to have engaged in forum shopping. The DARAB is ordered to proceed with the execution of the Decision dated 5 November 2001 of the Court of Appeals in CA-G.R. SP No. 57360, with dispatch. The respondents are found GUILTY of direct contempt and each is imposed a FINE of ₱2,000.00.
Ratio Decidendi
On the propriety of the remedy of annulment of judgment: The Supreme Court held that the petition for annulment of judgment could not prosper. An appropriate remedy, a petition for review on certiorari, was available to the petitioners before the Supreme Court, which they filed but was denied due to a procedural defect (lack of affidavit of service). Furthermore, neither extrinsic fraud nor lack of jurisdiction was present, as the petitioners were able to fully ventilate their claims before the PARAD and DARAB, which ruled in their favor. The Court noted that a petition for certiorari alleging grave abuse of discretion squarely falls within the jurisdiction of the CA, making a petition to annul the CA's judgment in such action without basis. On whether the respondents engaged in willful and deliberate forum shopping: The Court found that the respondents were guilty of forum shopping. They filed a petition for certiorari to assail the writ of execution pending appeal, despite a petition for review of the DARAB findings already pending before another division of the CA. The Court found substantial identity of parties, as the petitioners in both cases represented the same interest as heirs of Magdalena Sangalang. While the assigned errors differed, the ultimate relief sought in both petitions was the setting aside of the PARAD and DARAB decisions in favor of the petitioners. The Court emphasized that the petition for review was the appropriate vehicle to litigate the issues, and the filing of the certiorari petition was an attempt to circumvent the favorable judgment. The Court applied the principle that the first case filed, which is the petition for review, should prevail, and the decision in the certiorari case, which should have been dismissed, is null and void.
Main Doctrine
The filing of a petition for certiorari to assail a writ of execution pending appeal, when a petition for review of the main decision is already pending before another division of the appellate court, constitutes forum shopping, as it involves the same parties, subject matter, and reliefs sought, leading to the possibility of conflicting decisions. The petition for review, being the appropriate vehicle for litigating the issues, prevails over the petition for certiorari.