Santos Ventura Hocorma Foundation v. Mabalacat Institute
REITERATIONFacts
The Antecedents: Santos Ventura Hocorma Foundation, Inc. (SVHFI) is the registered owner of a parcel of land occupied by Mabalacat Institute, Inc. (MII) since 1983. SVHFI demanded rental payments from MII starting April 1, 2002, which MII refused. SVHFI then demanded payment for accrued rentals and threatened to vacate. Procedural History: SVHFI filed a Complaint for collection of a sum of money (Collection Case) against MII before the RTC of Makati City. MII filed a Motion to Dismiss, which was denied. MII's subsequent Petition for Certiorari before the CA was also denied, as was its Petition for Review on Certiorari before the Supreme Court. MII later filed its Answer with Counterclaim. Subsequently, SVHFI filed a Complaint for Ejectment (Ejectment Case) against MII before the MCTC of Mabalacat and Magalang, Pampanga. The RTC granted MII's Motion to Dismiss the Collection Case on the ground of forum shopping and splitting of cause of action. SVHFI appealed to the CA, which affirmed the RTC's dismissal. Both parties filed their respective Petitions for Review on Certiorari before the Supreme Court. The Supreme Court denied MII's petition (G.R. No. 211531) concerning its counterclaim. The Petition: SVHFI argues that the CA erred in sustaining the RTC's finding of forum shopping, asserting that the rights asserted in a collection of rent case differ from those in an ejectment proceeding.
Issue(s)
Whether SVHFI committed forum shopping when it filed the Ejectment Case while the Collection Case was pending. Whether an action for collection of sum of money may be joined with an ejectment suit.
Ruling
The Supreme Court granted SVHFI's Petition, reversed and set aside the Court of Appeals' Decision and Resolution, and remanded the case to the RTC of Makati City, Branch 150, for continuation of proceedings. The Court held that SVHFI was not guilty of forum shopping.
Ratio Decidendi
On the issue of forum shopping: The Court held that SVHFI did not violate the rule against forum shopping. The determinative factor in 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. The elements of forum shopping are: (i) identity of parties; (ii) identity of rights asserted and relief prayed for, founded on the same facts; and (iii) any judgment rendered in one action will amount to res judicata in the other. In this case, the second and third elements are lacking. There is no identity of rights asserted and reliefs prayed for between a suit for collection of sum of money and an unlawful detainer case. The sole issue in an ejectment proceeding is physical possession, while a collection case seeks payment of rentals. Any judgment in one would not amount to res judicata in the other. The Court cited Intramuros Administration v. Offshore Construction Development Co. and Lajave Agricultural Management and Development Enterprises, Inc. v. Spouses Javellana to support its reasoning. On the issue of joinder of causes of action: The Court reiterated that an action for collection of sum of money may not be joined with an ejectment suit, as this would constitute a misjoinder of causes of action under Section 5, Rule 2 of the Rules of Court. An action for collection is an ordinary civil action requiring a full-blown trial, while an ejectment suit is a special civil action requiring a summary procedure. The determination of the correct rental amount and the propriety of payment requires a full-blown trial, which cannot be accomplished in a summary proceeding. Therefore, the filing of the Ejectment Case subsequent to the Collection Case, while the latter was pending, did not constitute forum shopping because there was no identity of rights asserted and reliefs prayed for, and any judgment on one case would not amount to res judicata on the other.
Main Doctrine
The filing of an ejectment case and a collection of sum of money case, even if involving the same parties and property, does not constitute forum shopping if there is no identity of rights asserted and reliefs prayed for, and if a judgment in one case would not amount to res judicata in the other. Furthermore, an action for collection of sum of money may not be joined with an ejectment suit as it constitutes a misjoinder of causes of action.