G.R. No. 152576 ; May 5, 2003
INTRAMUROS ADMINISTRATION, petitioner, vs. YVETTE CONTACTO AND GREGORIO LUIS C. CONTACTO III, respondents.

FACTS

Petitioner Intramuros Administration and respondent Yvette Contacto entered into a five-year lease contract for the “Cantinas de Aduana” premises. During the lease, Contacto complained about the petitioner’s failure to evict sidewalk vendors and inadequate facilities, which allegedly caused her business losses. She eventually stopped paying rent. After failed restructuring agreements, the petitioner demanded payment and threatened closure. Contacto then filed Civil Case No. 96-767-44 (Branch 26, RTC Manila) for injunction, specific performance, and damages, seeking to prevent closure, offset her rehabilitation expenses, reduce rent, and obtain damages. A preliminary injunction was granted, allowing her to operate.
After the lease contract expired, the petitioner filed Civil Case No. 98-90835 (Branch 9, RTC Manila) against the respondents for collection of unpaid rentals, utility bills, and damages accruing from May 1995 until they vacated. The respondents moved to dismiss this second case on the ground of litis pendentia, citing the pending first case. The trial court denied the motion in a perfunctory order. The Court of Appeals reversed, granting the motion to dismiss on the ground of litis pendentia, prompting this petition.

ISSUE

Whether the filing of Civil Case No. 98-90835 is barred by litis pendentia due to the pendency of Civil Case No. 96-767-44.

RULING

The Supreme Court reversed the Court of Appeals, ruling that litis pendentia does not apply to bar the collection case in its entirety. The legal logic hinges on the requisites for litis pendentia: identity of parties, identity of rights asserted and relief prayed for, and identity where the relief in the second case would be barred by res judicata in the first. The Court found the first two requisites were present, as both cases involved the same parties and arose from the same lease contract. However, the third requisite was not fully satisfied. A judgment in the first case (for injunction and specific performance) would not constitute res judicata for all claims in the second collection case. The first case, filed in 1996, could only adjudicate rights and obligations that were due and demandable at the time of the petitioner’s answer therein. The collection case included claims for rentals and charges that accrued subsequently, particularly after the filing of the answer in the first suit. Therefore, litis pendentia could only bar claims that were already mature and could have been raised as a counterclaim in the first action at that time. Claims for obligations incurred after that point were not barred. The trial court’s order, while perfunctory, reached the correct result. The case was remanded for proceedings on claims arising after the filing of the answer in the first case.