G.R. No. 131502 ; June 8, 2000
WILSON ONG CHING KIAN CHUNG and THE DIRECTOR OF THE NATIONAL LIBRARY, petitioners, vs. CHINA NATIONAL CEREALS OIL AND FOODSTUFFS IMPORT AND EXPORT CORP., CEROILFOOD SHANDONG CEREAL AND OILS and BENJAMIN IRAO, JR., respondents.

FACTS

Petitioner Wilson Ong filed a complaint for copyright infringement before the Regional Trial Court (RTC) of Quezon City (Q-93-17628) against Lorenzo Tan, involving the label for vermicelli products. The Quezon City court issued a preliminary injunction in Ong’s favor. Subsequently, respondents China National Cereals and Benjamin Irao, Jr. filed a complaint for annulment of copyright before the RTC of Manila (Civil Case No. 94-68836) against Ong and the National Library Director, involving the same subject matter. The Manila court also issued a preliminary injunction against Ong. Ong moved to dismiss the Manila case on grounds of litis pendentia and forum shopping. The Court of Appeals, in a petition for certiorari (CA-G.R. SP No. 33178), annulled the Manila court’s order granting the injunction, ruling the case was dismissible for litis pendentia and forum shopping. Despite this CA decision becoming final, the Manila court proceeded and later rendered a judgment on the pleadings, ordering the cancellation of Ong’s copyright registration.

ISSUE

Whether the Regional Trial Court of Manila validly exercised jurisdiction over the complaint for annulment of copyright despite the prior pending action before the Quezon City court involving the same parties and subject matter.

RULING

The Supreme Court ruled in favor of the petitioners and annulled the decision of the Manila RTC. The legal logic is anchored on the doctrine of litis pendentia and the principle of judicial stability. The Quezon City court first acquired jurisdiction over the controversy when Ong filed his infringement case. The subsequent complaint for annulment filed in Manila involved substantially the same parties, rights, and reliefs, as both actions ultimately questioned the validity and ownership of the same copyright. Once a court of competent jurisdiction has acquired jurisdiction over a case, that jurisdiction excludes all other courts of concurrent jurisdiction from entertaining a substantially identical case. The Manila court, being a co-equal court, was devoid of authority to proceed and should have dismissed the case to avoid conflicting rulings and forum shopping. The Court of Appeals had already correctly identified these grounds. The Supreme Court emphasized that the Manila court’s failure to dismiss the case or order its consolidation with the first-filed Quezon City case constituted a violation of procedural rules designed to prevent multiplicity of suits. Consequently, the assailed judgment was declared null and void, and the Manila case was ordered dismissed without prejudice to the ongoing proceedings in Quezon City.