GR 163175; (June, 2008) (Digest)
G.R. No. 163175 ; June 27, 2008
CITY OF MAKATI, JEJOMAR BINAY and ERNESTO S. MERCADO, petitioners, vs. MUNICIPALITY (NOW CITY) OF TAGUIG, METROPOLITAN MANILA, THE EXECUTIVE SECRETARY, BASES CONVERSION AND DEVELOPMENT AUTHORITY, FORT BONIFACIO DEVELOPMENT CORPORATION, REGISTER OF DEEDS VICENTE A. GARCIA and THE LAND MANAGEMENT BUREAU DIRECTOR, respondents.
FACTS
This case involves a territorial dispute over portions of Fort Bonifacio. The Municipality (now City) of Taguig filed an action in 1993 (Civil Case No. 63896) before the Pasig RTC, seeking judicial confirmation that Fort Bonifacio is within its territorial jurisdiction and assailing Presidential Proclamations that transferred parts of the area to Makati. Subsequently, pursuant to Republic Act No. 7227 , President Ramos issued Executive Order No. 40 and Special Patents transferring specific lots within Fort Bonifacio, described as being in Barangay Fort Bonifacio, Taguig, to the Bases Conversion and Development Authority (BCDA) and the Fort Bonifacio Development Corporation (FBDC).
In 1996, the City of Makati, its officials, and concerned citizens filed a separate Petition for Prohibition and Mandamus (Civil Case No. 96-554) before the Makati RTC. They sought to restrain Taguig from exercising tax and regulatory powers over Fort Bonifacio and to stop the BCDA and FBDC from paying taxes to Taguig, arguing that the area is part of Makati. Taguig and FBDC moved to dismiss this petition.
ISSUE
Whether the Regional Trial Court of Makati correctly dismissed Civil Case No. 96-554.
RULING
Yes, the Supreme Court affirmed the dismissal. The core legal logic rests on the doctrine of lis pendens and the avoidance of multiplicity of suits. The Court found that the action filed by Makati in the Makati RTC involved the same fundamental issue—the territorial jurisdiction over Fort Bonifacio—as the earlier-filed case by Taguig in the Pasig RTC. Both cases essentially sought a judicial determination of which local government unit has authority over the disputed area, affecting the same parties’ rights and interests. The Makati petition, though framed as a special civil action for prohibition and mandamus to stop tax collections, ultimately required an adjudication on the boundary dispute, which was already pending in the Pasig case.
The Court emphasized that allowing the Makati case to proceed would constitute forum-shopping and could lead to conflicting decisions. The rule against multiplicity of suits requires the consolidation of all issues in a single proceeding to promote judicial economy and avoid contradictory rulings. Since the Pasig RTC had prior jurisdiction over the core territorial question, the Makati RTC acted correctly in dismissing the later-filed case. The proper recourse for Makati was to seek relief within the context of the already pending Pasig case, not to initiate a separate action.