GR 155622; (October, 2009) (Digest)
G.R. No. 155622; October 26, 2009
DOTMATRIX TRADING, represented by ROMY YAP CHUA, RENATO ROLLAN and ROLANDO D. CADIZ, Petitioner, vs. ROMMEL B. LEGASPI, doing business as BIG J FARMS and RBL FARM, Respondent.
FACTS
Petitioner Dotmatrix Trading and respondent Rommel Legaspi had a contract for the supply of day-old chicks. A dispute arose regarding payments and deliveries. Legaspi sent a demand letter for payment. Dotmatrix replied, claiming it had overpaid and demanding either delivery of a deficiency or a refund. Both parties subsequently filed separate complaints for sum of money and damages. On June 11, 2002, Dotmatrix filed its complaint before the RTC of Tarlac (Civil Case No. 9354) seeking a refund for alleged overpayment. On June 19, 2002, Legaspi filed his own complaint before the RTC of Malolos, Bulacan (Civil Case No. 489-M-2002) seeking payment for an alleged balance.
Upon being served summons in the Tarlac case, Legaspi moved to dismiss it on the ground of litis pendentia, arguing it was merely an anticipatory action filed to preempt his own collection case. The RTC-Tarlac granted the motion and dismissed Dotmatrix’s complaint. Dotmatrix’s motion for reconsideration was denied, prompting this petition.
ISSUE
Whether the RTC-Tarlac correctly dismissed Civil Case No. 9354 on the ground of litis pendentia, despite it being filed eight days prior to Civil Case No. 489-M-2002.
RULING
Yes, the dismissal was proper. The Supreme Court affirmed the RTC’s order, holding that all elements of litis pendentia were present. The parties in both suits are identical, and the causes of action arise from the same contract and set of facts involving the supply of day-old chicks. The reliefs sought, though phrased as opposing claims for money, are fundamentally interconnected; a judgment in one case regarding the exact obligation under the contract would constitute res judicata in the other.
The Court clarified that for litis pendentia to apply, it is not required that the action which must yield be the later-filed case. The rule requires merely another pending action, not a prior pending action. The determining factor is not strict chronological priority but the vexatious and unnecessary multiplicity of suits. The principle of qui prior est tempore, potior est jure (he who is first in time is stronger in right) is not an absolute rule in litis pendentia. The Court found that Dotmatrix filed its action only after receiving Legaspi’s demand, indicating it was a defensive, anticipatory suit. To prevent duplicative proceedings and conflicting judgments, the dismissal of one action was justified. The policy against multiplicity of suits prevails, and Legaspi’s case in Malolos can fully adjudicate the parties’ reciprocal obligations.