ABS-CBN Corporation v. Revillame
REITERATIONFacts
The Antecedents: ABS-CBN Corporation (ABS-CBN) and Willie B. Revillame (Revillame) entered into a three-year Agreement for Revillame to host the show "Wowowee." The relationship soured when Revillame demanded the firing of a co-host, Jobert Sucaldito, and threatened to resign. When ABS-CBN did not comply, Revillame withdrew from hosting and later sought to rescind the Agreement due to the cancellation of "Wowowee." ABS-CBN offered a replacement show, which Revillame found unsatisfactory, leading him to announce the rescission of the Agreement. ABS-CBN notified rival networks that Revillame's rescission was ineffectual. Revillame then filed a civil action seeking confirmation of the rescission and damages. ABS-CBN filed an Answer with Compulsory Counterclaims, seeking liquidated damages. ABS-CBN also filed a motion for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction to prevent Revillame from performing with a rival network (TV5) on a similar show, arguing he was still bound by their Agreement. The RTC denied the TRO but ordered Revillame to post a bond. ABS-CBN assailed this before the CA, which was denied. Revillame posted a surety bond (AIPC Bond). ABS-CBN questioned the authenticity of Revillame's signatures on the bond and sought its examination. The RTC issued several orders regarding the examination of the bond, which were elevated to the CA. Meanwhile, ABS-CBN filed a separate Copyright Infringement Case against Revillame and others. The CA dismissed this case, ruling ABS-CBN engaged in forum shopping by filing both the counterclaim and the copyright infringement complaint based on the same cause of action. This ruling was affirmed by the Supreme Court in G.R. No. 201664. Subsequently, the RTC dismissed ABS-CBN's compulsory counterclaim on the ground of forum shopping and discharged the AIPC Bond. Procedural History: Three consolidated petitions were filed. G.R. No. 221781 by ABS-CBN assailing the CA's dismissal of Revillame's petition on mootness. G.R. No. 225095 by ABS-CBN assailing the CA's dismissal of its petition for failing to show grave abuse of discretion by the RTC. G.R. No. 236167 by Revillame assailing the CA's reinstatement of ABS-CBN's compulsory counterclaims. The CA in CA-G.R. SP 122086 dismissed Revillame's petition on mootness, noting the RTC's recall of the order for bond examination and Revillame's new contract with another network. The CA in CA-G.R. SP 122154 dismissed ABS-CBN's petition, finding no grave abuse of discretion and noting Revillame's admission of signing the bond. The CA in CA-G.R. CV No. 100369 partially reversed the RTC, reinstating ABS-CBN's compulsory counterclaims, holding that the expiration of the agreement did not moot the claims and that judicial courtesy should be observed. The Supreme Court reviewed these decisions. The Petition: The Supreme Court consolidated the three petitions to resolve the issues concerning forum shopping, res judicata, mootness, and the reinstatement of counterclaims.
Issue(s)
Whether the Court of Appeals erred in dismissing Revillame's petition on the ground of mootness. Whether the Court of Appeals erred in dismissing ABS-CBN's petition for failing to show grave abuse of discretion by the Regional Trial Court. Whether the Court of Appeals erred in reinstating ABS-CBN's compulsory counterclaims despite findings of forum shopping. Whether the issues concerning the examination of the AIPC Bond are moot and academic. Whether the issue of judicial courtesy is still relevant in light of prior rulings on forum shopping.
Ruling
The Petitions in G.R. No. 221781 and 225095 are dismissed. The Petition in G.R. No. 236167 is partly granted. The Court reversed the Court of Appeals' decision in CA-G.R. CV No. 100369 insofar as it reinstated ABS-CBN's compulsory counterclaims, declaring them dismissed with prejudice.
Ratio Decidendi
On the CA's dismissal of Revillame's petition (G.R. No. 221781): The Court affirmed the CA's dismissal of Revillame's petition on the ground of mootness. The CA correctly observed that the RTC had already recalled the order permitting the examination of the bond, and that Revillame had entered into a new contract with another network, GMA. These supervening events rendered the issues raised by Revillame regarding the examination of the bond no longer justiciable, as there was no substantial relief that could be granted. The Court found no reversible error in the CA's application of the doctrine of mootness. On the CA's dismissal of ABS-CBN's petition (G.R. No. 225095): The Court agreed with the CA's dismissal of ABS-CBN's petition, finding that it failed to demonstrate that the RTC committed grave abuse of discretion. The CA correctly noted that ABS-CBN's direct recourse to the CA via a Rule 65 petition without first filing a motion for reconsideration was not justified. Furthermore, the CA found that Revillame's admission of signing the bond, while self-serving, effectively eliminated ABS-CBN's concern about the bond's genuineness, making the issue of examination less critical. The CA's affirmation of the RTC's Amended Order was thus upheld. On the issue of forum shopping and res judicata (G.R. No. 236167) and reinstatement of counterclaims: The Court held that the issue of forum shopping had already been settled with finality by this Court in G.R. No. 201664, which affirmed the CA's finding that ABS-CBN was guilty of forum shopping in filing a copyright infringement complaint while simultaneously pursuing a compulsory counterclaim based on the same cause of action. This prior ruling operates as res judicata by conclusiveness of judgment between the same parties, ABS-CBN and Revillame. The Court emphasized that deliberate and willful forum shopping is a punitive measure that warrants the dismissal of all cases instituted by the guilty party. The Court found that ABS-CBN's filing of the copyright infringement complaint a month after its TRO application was denied, on similar grounds, demonstrated a willful intent to seek the same relief in different fora. Consequently, ABS-CBN's compulsory counterclaim was correctly dismissed by the RTC, and the CA's reinstatement of these counterclaims was erroneous. The Court reversed the CA's ruling that reinstated ABS-CBN's compulsory counterclaims. The Court reiterated that forum shopping is a serious offense that warrants punitive measures, including the dismissal of all related pleadings. Therefore, the compulsory counterclaim, having been found to be a product of forum shopping, should remain dismissed. On the mootness of issues related to the AIPC Bond (G.R. No. 221781 and G.R. No. 225095): The Court found that the issues raised by ABS-CBN concerning its right to examine the AIPC Bond and the authenticity of Revillame's signatures thereon were rendered moot and academic by the RTC's Order discharging the bond. The discharge of the bond meant that Revillame was released from any obligation to answer for contingent damages ABS-CBN might incur, rendering the examination of the bond no longer necessary or practical. The Court reiterated that it generally declines jurisdiction over moot cases as adjudication would serve no useful purpose and could result in mere advisory opinions. The Court noted that the AIPC Bond was no longer an integral part of the court records, further solidifying the mootness of the issue. On the reinstatement of counterclaims and judicial courtesy (G.R. No. 236167): The principle of judicial courtesy invoked by the CA did not override the established finding of forum shopping, which is a ground for dismissal.
Main Doctrine
Deliberate and willful forum shopping is a cause for the dismissal of a compulsory counterclaim, and the principle of res judicata by conclusiveness of judgment applies to issues already resolved in a prior case between the same parties. Issues that have become moot and academic due to supervening events, such as the discharge of a bond, will not be adjudicated by the Court.