GR 158455; (June, 2005) (Digest)
G.R. No. 158455; June 28, 2005
SHERWILL DEVELOPMENT CORPORATION, petitioner, vs. SITIO STO. NIÑO RESIDENTS ASSOCIATION, INC. and/or NILDA DEVILLERES, and the LANDS MANAGEMENT BUREAU, respondents.
FACTS
Petitioner Sherwill Development Corporation, the registered owner of two parcels of land in Muntinlupa, filed a Complaint for quieting of title against the respondents. Sherwill alleged that the private respondents, members of a residents association, were unlawfully occupying the lots and, through a pending administrative case (LMB Case No. 7-98 before the Lands Management Bureau), were seeking to nullify its Transfer Certificates of Title (TCTs). As part of its prayer, Sherwill sought a writ of preliminary injunction to order the LMB to cease proceedings in the administrative case, arguing that its titles were long indefeasible.
The private respondents moved to dismiss the civil case on grounds of litis pendentia and forum shopping. They contended that the administrative case and the civil action involved the same parties, the same subject properties, and the same fundamental issue regarding the validity of Sherwill’s titles. The Regional Trial Court (RTC) granted the motion and dismissed the civil action.
ISSUE
Whether the RTC correctly dismissed the complaint for quieting of title on the grounds of litis pendentia and forum shopping.
RULING
Yes, the Supreme Court affirmed the RTC’s dismissal. The Court applied the elements of litis pendentia: (1) identity of parties, or at least such parties as represent the same interests in both actions; (2) identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (3) identity of the two cases such that judgment in one, regardless of which party is successful, would amount to res judicata in the other. All requisites were present.
There was identity of parties, as Sherwill and the private residents association were opposing parties in both the LMB case and the RTC case. The rights asserted and the reliefs ultimately sought were identical: the core issue in both proceedings was the validity of Sherwill’s TCTs and, consequently, the question of who had a better right to the properties. A judgment in the LMB case, which could recommend reversion of the land to the state or nullification of the titles, would constitute res judicata on the issue of title validity in the quieting of title case. The Court emphasized that the pendency of an administrative case, which is a prejudicial question, bars a simultaneous judicial action involving the same issue. Since the elements of litis pendentia were established, the filing of the civil action also constituted forum shopping. The RTC, therefore, correctly dismissed the petition.