Zamora v. Quinan
REITERATIONFacts
The Antecedents: Petitioner Bernardo S. Zamora filed a Complaint for Reconveyance of Title of Real Properties against respondents, alleging that the properties were fraudulently obtained by the respondents. This action stemmed from respondents' prior filing of a Petition for the Issuance of New Duplicate Certificate of Title, which was granted by the Regional Trial Court (RTC) of Cebu City, Branch 9. Petitioner claimed to be in possession of the original Transfer Certificates of Title. Procedural History: While his reconveyance case was pending before the RTC of Cebu City, Branch 19, petitioner initiated multiple actions. He first filed a Petition for Annulment of Judgment before the Court of Appeals (CA), Cebu City, which was dismissed on technicalities. Subsequently, he filed another civil action before the CA for Annulment of Judgment. The RTC of Cebu City, Branch 19, dismissed petitioner's original reconveyance case due to forum shopping. Thereafter, respondents filed a motion to dismiss the second CA petition, also on grounds of forum shopping, which the CA granted. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner seeks review of the CA's resolutions dismissing his petition for annulment of judgment due to forum shopping. He argues that the CA erred in dismissing his case on technicalities and in disregarding jurisprudence that would render the reconstituted titles void. Petitioner contends that the CA should have relaxed procedural rules to allow him an opportunity to be heard and to present his claim that the owner's duplicate copies of the titles were never lost, thus the reconstituted titles are void. The petition is filed under Rule 45 of the Rules of Court.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for annulment of judgment on the ground of forum shopping. Whether the Court of Appeals erred in disregarding the ruling in Camitan v. Fidelity Investment Corporation concerning void reconstituted titles when the owner's duplicate copy was not lost.
Ruling
The Petition for Review on Certiorari is DENIED for lack of merit. The Resolution dated July 31, 2014, and Resolution dated November 27, 2014, of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the issue of forum shopping: The Court affirmed the CA's finding that petitioner committed forum shopping. There was an identity of parties, causes of action, and reliefs sought in the reconveyance case filed before the RTC and the petition for annulment of judgment filed before the CA. The petitioner sought to recover property wrongfully registered in respondents' names in the reconveyance case, postulating that respondents knew petitioner possessed the original owner's duplicate copies of the titles. In the annulment case, he sought the nullification of the decision for the issuance of new titles, arguing the RTC never acquired jurisdiction because the reconstituted title was void as the duplicate copy was not lost but in petitioner's possession. Both actions aimed at the revocation and cancellation of the new certificates of title in respondents' names and the recovery or consolidation of title in petitioner's favor, founded on the same facts. A favorable judgment in the reconveyance case would amount to res judicata in the annulment action, creating the possibility of conflicting decisions. The Court reiterated that forum shopping trifles with the courts, abuses their processes, degrades the administration of justice, and adds to congested dockets. Prudence dictated that petitioner await the RTC's decision in the reconveyance case before seeking other remedies. The acts of a party or counsel clearly constituting willful and deliberate forum shopping are grounds for summary dismissal with prejudice, direct contempt, and administrative sanctions. On the issue of disregarding jurisprudence regarding void reconstituted titles: While the Court acknowledged the petitioner's argument based on Camitan v. Fidelity Investment Corporation, it found that the primary ground for dismissal by the CA was forum shopping, which was a valid and decisive reason. The Court's resolution focused on the procedural defect of forum shopping rather than the substantive merits of the reconveyance claim or the validity of the reconstituted titles. The existence of forum shopping rendered the subsequent petition unnecessary and vexatious, and the CA's dismissal was upheld on this basis.
Main Doctrine
Forum shopping is committed when a party institutes two or more suits in different courts, either simultaneously or successively, to ask the courts to rule on the same or related causes or to grant the same or substantially the same reliefs, on the supposition that one or the other court would make a favorable disposition or increase a party's chances of obtaining a favorable decision. The test for determining forum shopping is whether the elements of litis pendentia are present, or whether a final judgment in one case will amount to res judicata in another, which requires identity of parties, rights or causes of action, and reliefs sought.