G.R. No. 171247 , July 22, 2015.
ALFREDO L. VILLAMOR, JR., Petitioner, vs. HON. AMELIA C. MANALASTAS, PRESIDING JUDGE, RTC-PASIG CITY, BRANCH 268, and LEONARDO S. UMALE [deceased] substituted by his spouse, CLARISSA VICTORIA UMALE, Respondents.

FACTS

This case stemmed from a complaint filed by Leonardo S. Umale against Alfredo L. Villamor, Jr. and others with the RTC of Pasig City to compel the petitioner to account for and deliver rental payments. The case was re-raffled to Branch 268 presided by Judge Amelia C. Manalastas. The petitioner filed multiple Motions for Inhibition to disqualify Judge Manalastas, citing that she stood as a godparent with the respondent for a child of a common friend, and that the law firm Ponce Enrile Reyes and Manalastas had written to him on a claim similar to the respondent’s. Judge Manalastas denied the Motions for Inhibition via an Omnibus Order dated October 17, 2005. On November 3, 2005, the petitioner filed a Motion for Reconsideration with Motion to Lift Order of Default (MR with Motion to Lift Default Order) with the RTC, assailing the Omnibus Order. On November 7, 2005, the petitioner filed a Petition for Certiorari with the Court of Appeals assailing the Omnibus Order’s denial of his Motions for Inhibition. Subsequently, on November 12, 2005, the petitioner filed with the RTC a Motion for Inhibition of Presiding Judge on Account of Institution of Administrative Case, based on an administrative complaint he filed against Judge Manalastas on November 11, 2005. The respondent moved to dismiss the CA petition on grounds of forum shopping, citing the pendency of the MR and the subsequent Motion for Inhibition in the RTC. The CA dismissed the petition, finding that the petitioner engaged in forum shopping by seeking the same relief—the inhibition of Judge Manalastas—in multiple forums simultaneously.

ISSUE

1. Whether the petitioner engaged in forum shopping.
2. Whether Judge Manalastas’s decision to continue hearing the civil case was improper.

RULING

1. Yes, the petitioner engaged in forum shopping. Forum shopping exists when a party institutes two or more suits in different courts, simultaneously or successively, to rule on the same or related causes and/or to grant the same or substantially the same reliefs. The elements of litis pendentia—identity of parties, causes of action, and reliefs sought—were present. At the time the petitioner filed the Petition for Certiorari with the CA, his MR with Motion to Lift Default Order, which also sought reconsideration of the Omnibus Order including the denial of inhibition, was still pending with the RTC. He subsequently filed another Motion for Inhibition in the RTC based on the administrative complaint. All these pleadings sought the same relief: the inhibition of Judge Manalastas. The CA correctly dismissed the petition for forum shopping.
2. No, Judge Manalastas’s decision to continue hearing the civil case was not improper. A judge’s decision not to inhibit must be based on just and valid causes. The grounds raised by the petitioner—that the judge stood as a godparent with the respondent and that her former law firm wrote a letter on a similar claim—were insufficient to prove bias or partiality. The mere filing of an administrative complaint against a judge is not a mandatory ground for inhibition; otherwise, litigants could easily manipulate proceedings. The judge correctly relied on the presumption of regularity and impartiality in the performance of judicial functions.