GR 138137; (March, 2001) (Digest)
G.R. No. 138137 ; March 8, 2001
PERLA S. ZULUETA, petitioner, vs. ASIA BREWERY, INC., respondent.
FACTS
Petitioner Perla Zulueta, a dealer of respondent Asia Brewery, Inc., filed a Complaint for Breach of Contract, Specific Performance, and Damages before the RTC of Iloilo (Civil Case No. 20341), alleging violations of their Dealership Agreement. During its pendency, respondent filed a separate Complaint for a sum of money before the RTC of Makati (Civil Case No. 94-2110), seeking to collect payment for delivered beer products. Petitioner moved to dismiss the Makati case, arguing it split a cause of action, but the motion was denied. Subsequently, petitioner moved for the consolidation of the Makati case with the earlier-filed Iloilo case. The Makati RTC granted the consolidation. Respondent challenged this order via a Petition for Certiorari before the Court of Appeals.
ISSUE
The primary issue is whether the Makati RTC correctly ordered the consolidation of the later-filed collection case with the earlier-filed breach of contract case.
RULING
The Supreme Court granted the petition and reinstated the consolidation order. It held that consolidation was proper under the circumstances. The Court clarified that while the Court of Appeals focused on a perceived lack of common issues—viewing the collection case as a simple debt issue and the Iloilo case as a breach of contract issue—this was a myopic view. The legal logic is that the obligation to pay for the delivered beer products, which is the subject of the Makati case, is inextricably linked to the contractual relations governed by the Dealership Agreement, which is the core subject of the Iloilo case. The transactions and liabilities in both cases stem from the same contractual relationship between the identical parties. Consolidation is mandated when cases involve the same parties and closely related subject matters to serve the best interests of the parties, settle all issues expeditiously, avoid the possibility of conflicting decisions, and promote judicial economy. The venue of the first-filed case (Iloilo) was proper, and it was more practical and convenient to have all related incidents resolved in a single forum. Therefore, the trial court correctly exercised its discretion in ordering consolidation.