G.R. No. 160214 December 16, 2005
GAUDENCIA NAVARRO VDA. DE TAROMA, et al., Petitioners, vs. SPS. FELINO N. TAROMA and LYDIA MARTINEZ, et al., Respondents.

FACTS

Petitioners filed a complaint for annulment of title, which was dismissed by the Municipal Circuit Trial Court (MCTC). Their appeal to the Regional Trial Court (RTC) was likewise dismissed. They then filed a Petition for Review with the Court of Appeals (CA). While this petition was pending, petitioners filed an amended petition. The CA subsequently rendered a Decision dismissing the original petition for lack of merit. Petitioners filed a motion for reconsideration of this CA Decision.
The day after filing said motion for reconsideration, petitioners filed a Petition for Review on Certiorari (G.R. No. 157393) before the Supreme Court, seeking to annul the same CA Decision. The Supreme Court’s First Division denied this petition for procedural deficiencies and subsequently denied petitioners’ motion for reconsideration with finality. An Entry of Judgment was issued.

ISSUE

Whether the Court of Appeals correctly noted without action petitioners’ subsequent “Brief Motion for Reconsideration” of its resolution which declared their first motion for reconsideration abandoned.

RULING

Yes. The Court of Appeals acted correctly. The Supreme Court affirmed that petitioners were guilty of forum shopping and that their actions violated the rule on finality of judgments. By filing a Petition for Review with the Supreme Court while their motion for reconsideration of the CA Decision was still pending, petitioners effectively elected to seek relief from the higher court. This act constituted an abandonment of their pending motion for reconsideration before the CA, as explicitly provided under the 2002 Internal Rules of the Court of Appeals.
The legal logic is clear: a party cannot pursue simultaneous remedies in different courts for the same relief concerning the same judgment. This rule prevents forum shopping, ensures judicial economy, and upholds the hierarchy of courts. Having invoked the Supreme Court’s jurisdiction, petitioners were deemed to have withdrawn from the Court of Appeals. Consequently, the CA lost jurisdiction over the case upon the filing of the Supreme Court petition. The subsequent denial of that Supreme Court petition rendered the CA Decision final and executory. Petitioners’ later attempt to revive the case before the CA via a “Brief Motion for Reconsideration” was a futile effort to reopen a matter already laid to rest. The doctrine of finality of judgment precludes the re-litigation of a settled issue to ensure the conclusiveness of adjudication.