G.R. No. 144705 November 15, 2005
NANCY L. TY, Petitioner, vs. BANCO FILIPINO SAVINGS & MORTGAGE BANK, Respondent.

FACTS

Respondent Banco Filipino filed a complaint for reconveyance against petitioner Nancy L. Ty and others concerning two specific lots in Manila. Banco Filipino alleged that these properties, along with others nationwide, were transferred to defendant Tala Realty under an implied trust arrangement established by a 1979 board resolution, as part of a scheme to circumvent banking laws on real estate holdings. Petitioner moved to dismiss the complaint on grounds including lack of jurisdiction, litis pendentia, and lack of cause of action. She argued that multiple suits involving the same 1979 resolution and the same core issue of an implied trust were pending in various Regional Trial Courts (RTCs) across the country, constituting forum shopping.
The RTC granted the motion to dismiss, finding a violation of Administrative Circular No. 04-94 on forum shopping. The trial court ruled that all the reconveyance cases filed by Banco Filipino shared an identity of causes of action (breach of the alleged trust), issues (existence of a trust relationship), and subject matter (properties held under the same trust agreement), despite the properties being different. The Court of Appeals (CA) reversed this dismissal and reinstated the complaint. The CA emphasized the differences in the specific properties, their locations, the deeds of conveyance, and the parties involved in the various suits.

ISSUE

Whether the Court of Appeals erred in reinstating the complaint by ruling that the doctrine of litis pendentia and the rule against forum shopping did not apply.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The legal logic rests on the principle of conclusiveness of judgment, also known as the “law of the case” doctrine. The Court noted that the specific issue of whether Banco Filipino was guilty of forum shopping and litis pendentia for filing multiple reconveyance suits based on the same 1979 board resolution had already been squarely addressed and settled in a prior related case, G.R. No. 139166, where the Court ruled in favor of Banco Filipino. In that prior decision, the Court found no forum shopping because each complaint sought recovery of a specific, distinct property, giving rise to separate causes of action.
Consequently, this prior ruling constitutes a binding precedent on the same issue between the same parties. To allow petitioner to re-litigate the identical issue would create conflicting decisions and undermine judicial stability and finality. The Court held that the matter was already laid to rest; revisiting it would render the earlier final judgment inutile. Therefore, having been conclusively determined in the earlier case that the filing of separate suits for different properties did not constitute forum shopping or litis pendentia, the RTC’s dismissal on that ground was incorrect, and the CA properly reinstated the complaint for trial on the merits.