G.R. No. 108451 . April 11, 1997.
SOLID HOMES, INC., petitioner, vs. HON. COURT OF APPEALS, and EVELYN VERGEL DE DIOS, respondents.

FACTS

Petitioner Solid Homes, Inc. acquired a parcel of land in Bulacan from Santiago Papa, which included an interest in a quarry permit. After the permit lapsed, private respondent Evelyn Vergel De Dios applied for and was granted a Small Scale Mining Permit over the same property by the DENR. Solid Homes protested this grant before the DENR, arguing its priority rights as the landowner. While its administrative protest was pending appeal with the DENR Secretary, Solid Homes also filed a complaint for quieting of title with the Regional Trial Court (RTC) of Bulacan.
In the RTC case, Solid Homes sought a writ of preliminary injunction to restrain De Dios from conducting mining operations, alleging that her permit cast a cloud on its title. The RTC denied the application for injunction, citing lack of jurisdiction under P.D. No. 605, which prohibits courts from issuing injunctions in cases involving the issuance of licenses or permits for the development of natural resources. Solid Homes then filed a petition for certiorari with the Court of Appeals (CA), which affirmed the RTC’s order.

ISSUE

Whether the Court of Appeals acted with grave abuse of discretion in affirming the trial court’s denial of the application for a preliminary injunction and in ruling that Solid Homes was guilty of forum-shopping.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. On the jurisdictional issue, the Court upheld the trial court’s denial of the injunction application. P.D. No. 605 explicitly strips courts of jurisdiction to issue restraining orders or injunctions in any case involving the issuance or approval of permits for the exploitation of natural resources. Since the core of Solid Homes’ complaint sought to nullify the mining permit granted by the DENR, the trial court correctly refrained from granting injunctive relief, as doing so would interfere with the administrative agency’s prerogative.
More critically, the Court found Solid Homes guilty of forum-shopping. The test for forum-shopping is whether the elements of litis pendentia are present or where a final judgment in one case would amount to res judicata in the other. Here, Solid Homes was simultaneously pursuing two remedies in different fora for the same relief: the cancellation of De Dios’s mining permit. It raised identical issues and sought substantially the same outcome in its pending administrative appeal before the DENR Secretary and in its judicial action for quieting of title. This practice vexes the courts and creates the risk of conflicting decisions. Consequently, the Court of Appeals correctly dismissed the petition on this ground.