GR 154618; (April, 2004) (Digest)
G.R. No. 154618; April 14, 2004
AGILENT TECHNOLOGIES SINGAPORE (PTE) LTD., petitioner, vs. INTEGRATED SILICON TECHNOLOGY PHILIPPINES CORPORATION, et al., respondents.
FACTS
Petitioner Agilent Technologies Singapore, an unlicensed foreign corporation, and respondent Integrated Silicon Technology Philippines entered into a Value Added Assembly Services Agreement (VAASA), originally with Hewlett-Packard Singapore, which Agilent later assumed. The VAASA involved Integrated Silicon manufacturing fiber optics using Agilent’s consigned materials and machinery. Upon the agreement’s expiration, Integrated Silicon filed a complaint for Specific Performance and Damages (Civil Case No. 3110-2001-C) against Agilent, alleging breach of an oral agreement to extend the VAASA. Subsequently, Agilent filed its own complaint (Civil Case No. 3123-2001-C) against Integrated Silicon and its officers for Specific Performance, Recovery of Possession, and Sum of Money, seeking a writ of replevin to recover its equipment and materials left at Integrated Silicon’s plant.
Respondents moved to dismiss Agilent’s complaint on grounds including lack of capacity to sue, litis pendentia, and forum shopping. The Regional Trial Court denied the motion and granted Agilent’s application for a writ of replevin. Respondents filed a petition for certiorari with the Court of Appeals without a prior motion for reconsideration. The Court of Appeals granted the petition, annulled the RTC order, and dismissed Civil Case No. 3123-2001-C, citing litis pendentia and forum shopping due to the first-filed case.
ISSUE
Whether the Court of Appeals erred in dismissing Civil Case No. 3123-2001-C on the grounds of litis pendentia and forum shopping.
RULING
Yes, the Court of Appeals committed reversible error. The Supreme Court reinstated the RTC order and granted Agilent’s application for a writ of replevin. On procedural grounds, the failure to file a motion for reconsideration was excusable because the Court of Appeals incorrectly treated the RTC order as a nullity for lack of jurisdiction. Jurisdiction is conferred by law, and the RTC had jurisdiction over the subject matter. On substantive grounds, the elements of litis pendentia were not present. The two cases involved different causes of action and reliefs. The first case by Integrated Silicon was for specific performance of an alleged oral extension and damages. The second case by Agilent was essentially an action for recovery of personal property (replevin) based on its ownership of the equipment and materials. The parties were also not identical, as the defendants in each suit differed. Consequently, there was no forum shopping, as the actions did not involve the same transactions, issues, and essential facts. The Supreme Court clarified that a foreign corporation not licensed to do business but suing on an isolated transaction is not barred from accessing Philippine courts.