GR 160841; (June, 2010) (Digest)
G.R. No. 160841; June 23, 2010
LEY CONSTRUCTION & DEVELOPMENT CORPORATION, LC BUILDERS & DEVELOPERS, INC., METRO CONTAINER CORPORATION, MANUEL T. LEY, and JANET C. LEY, Petitioners, vs. PHILIPPINE COMMERCIAL & INTERNATIONAL BANK, EX-OFFICIO SHERIFF OF THE REGIONAL TRIAL COURT OF VALENZUELA, METRO MANILA, AND CLERK OF COURT AND EX-OFFICIO SHERIFF OF THE REGIONAL TRIAL COURT OF PASIG, METRO MANILA, Respondents.
FACTS
Petitioners obtained multiple loans from respondent PCIB, secured by real estate and chattel mortgages. Upon default, PCIB initiated extrajudicial foreclosure proceedings. To enjoin the foreclosure sales, petitioners filed a Complaint for injunction and damages (Civil Case No. 91-2495) before the Makati RTC in 1991. The case saw protracted litigation, including the issuance and subsequent lifting of a preliminary injunction, and petitioners’ filing of two other related complaints in Manila, which were dismissed for forum shopping and litis pendentia.
During the pendency of a separate petition (G.R. No. 114951) before the Supreme Court, which challenged an order lifting the injunction, the Makati RTC issued the Order dated July 28, 1994, dismissing Civil Case No. 91-2495 for failure to prosecute. Petitioners appealed this dismissal to the Court of Appeals, which dismissed their appeal for being filed out of time. Petitioners then elevated the case to the Supreme Court via this Petition for Review.
ISSUE
Whether the Supreme Court should resolve the petition assailing the dismissal of Civil Case No. 91-2495 for failure to prosecute.
RULING
The Supreme Court denied the petition. The legal logic is grounded on the principle of finality of judgment and conclusiveness of judgment, which bars the relitigation of issues already settled in a prior final decision. The Court noted that while the instant petition sought review of the dismissal for failure to prosecute, the very same Civil Case No. 91-2495 had already been the subject of a final and executory judgment in G.R. No. 114951.
In that prior case, the Supreme Court had definitively ruled on the dismissibility of Civil Case No. 91-2495, finding petitioners guilty of forum shopping and ordering the complaint dismissed with prejudice. Therefore, the issue of whether Civil Case No. 91-2495 should be dismissed had already been conclusively adjudicated. To entertain the present petition, which effectively seeks a review of the same case’s dismissibility on a different procedural ground, would violate the doctrine of finality and allow endless litigation. The Court held it would be inimical to the orderly administration of justice to reopen a matter already closed by a final judgment.