Taguig v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners, Municipality of Taguig, its Mayor Ricardo Papa, Jr., and Chief of the General Service Office Roberto Santos, were in a dispute with respondent Barangay Hagonoy, Taguig, over the ownership and control of the Hagonoy Multi-Purpose Hall. On December 8, 1999, Barangay Hagonoy filed a complaint for damages with a prayer for a writ of preliminary injunction and temporary restraining order (TRO) against petitioners before the Regional Trial Court (RTC) of Pasig, docketed as Civil Case No. 67720. The RTC issued a 72-hour TRO, which was later extended to 20 days. Procedural History: On December 13, 1999, petitioners filed a petition for certiorari and prohibition with application for a preliminary injunction before the Court of Appeals (CA) (CA-G.R. SP No. 56211), assailing the RTC's order extending the TRO. The CA issued a cease and desist order for 60 days. However, on December 16, 1999, the CA lifted this order, finding that Barangay Hagonoy had been in possession of the hall since 1996 and its continued possession would not prejudice petitioners. The CA directed the RTC to resolve Civil Case No. 67720 speedily. On December 17, 1999, the RTC granted Barangay Hagonoy's application for a writ of preliminary injunction. On December 22, 1999, petitioners filed a motion to withdraw their first CA petition. On the same day, petitioners filed a second petition for certiorari and prohibition with application for a preliminary injunction before the CA (CA-G.R. SP No. 56369), assailing the RTC's December 17, 1999 order granting the preliminary injunction. This second petition was dismissed by the CA on February 2, 2000, for violating the rule against forum shopping. The CA found that the second petition was filed while the first was still pending, and the motion to withdraw was filed only after the second petition was instituted. The CA's denial of the motion for reconsideration led to the present petition for review on certiorari before the Supreme Court. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to annul the CA's resolutions dismissing their second petition for forum shopping. They argued that no forum shopping was committed because the second petition was filed after a motion to withdraw the first was made, that both petitions assailed different orders, and that no decision had been rendered in the first petition. They also contended that filing two petitions in the same court (CA) does not constitute forum shopping.
Issue(s)
Whether the petitioners committed forum shopping by filing a second petition for certiorari and prohibition with the Court of Appeals while a similar petition involving the same parties and issues was still pending. Whether the Court of Appeals erred in dismissing the second petition on the ground of forum shopping.
Ruling
The petition for review on certiorari is denied, and the Resolutions dated February 2, 2000, and March 20, 2000, of the Court of Appeals are affirmed. The Court found that the petitioners committed forum shopping.
Ratio Decidendi
On the Issue of Forum Shopping: Forum shopping is defined as the act of filing multiple suits or actions based on the same cause and seeking the same relief, which constitutes malpractice and an abuse of court processes. The Court reiterated that the vexation caused to courts and parties-litigants by a party who asks different courts and/or administrative agencies to rule on the same or related causes and/or grant the same or substantially the same reliefs, in the process creating the possibility of conflicting decisions being rendered by the different fora upon the same issues, is the core concern. In this case, although the petitioners assailed two different orders of the RTC (one extending a TRO and another granting a preliminary injunction), the objective and relief sought in both petitions for certiorari and prohibition filed with the CA were the same: to prevent the respondent judge from enjoining petitioners from taking over, control, and possession of the Hagonoy Multi-Purpose Hall and from further proceeding with Civil Case No. 67720. The Court found that the second petition was filed while the first was still pending, and the motion to withdraw the first was filed only after the second petition was instituted, clearly indicating a deliberate attempt to circumvent the rule against forum shopping. The fact that the petitions were filed with different divisions of the same appellate court does not negate the existence of forum shopping, as the principle applies equally to multiple petitions within the same tribunal or agency, citing Silahis International Hotel, Inc. vs. NLRC. On the Issue of the Propriety of the Dismissal: The Court emphasized that the petitioners' claim of good faith was unpersuasive, as they failed to advance a valid reason for filing the second petition other than the perceived mootness of the first due to the issuance of the preliminary injunction. The Court noted that unlike in the Gordon case, where the second petition was filed to comply with the hierarchy of courts, here, the petitioners sought to improve their chances of obtaining a favorable writ of preliminary injunction by having the case raffled to another division after the first division had already dissolved its cease and desist order. The Court concluded that the CA correctly dismissed the second petition on the ground of forum shopping, as it is a contumacious act penalized by summary dismissal.
Main Doctrine
Forum shopping is the act of filing multiple suits or actions based on the same cause and seeking the same relief, which constitutes malpractice and an abuse of court processes. This prohibition applies even when multiple petitions are filed before different divisions of the same appellate court, as it leads to the vexation of courts and parties-litigants and the possibility of conflicting decisions. Such conduct warrants summary dismissal of the petitions and may be subject to further sanctions.