G.R. No. 171525; July 23, 2010
ST. CATHERINE REALTY CORPORATION and LAND KING REALTY DEVELOPMENT CORPORATION, Petitioners, vs. FERDINAND Y. PINEDA and DOLORES S. LACUATA, Respondents.

FACTS

Respondents Ferdinand Pineda and Dolores Lacuata purchased parcels of land from George Lizares in 1991. The properties were later placed under the land reform program, and emancipation patents were issued to agricultural tenants in 1993. In 1994, respondents filed an action for specific performance against Lizares (Civil Case No. 10265) to compel the registration of the sale. This case was eventually dismissed by the trial court, a dismissal which became final and executory after the Supreme Court denied a related petition in G.R. No. 143492. Separately, Lizares’s own challenge to the agrarian reform coverage was dismissed by the DARAB and the Court of Appeals.
In 2001, while G.R. No. 143492 was still pending, respondents filed a new complaint (Civil Case No. 12194) against petitioners St. Catherine Realty and Land King Realty, subsequent buyers of the disputed land, for annulment of titles and damages. Petitioners moved to dismiss the complaint on the ground that respondents submitted a false certification against forum shopping, as it failed to disclose the then-pending G.R. No. 143492. The trial court initially granted the dismissal but later reinstated the complaint. Petitioners elevated the matter via certiorari to the Court of Appeals, which upheld the trial court’s reinstatement order.

ISSUE

Whether the Court of Appeals erred in not dismissing Civil Case No. 12194 due to respondents’ failure to comply with the certification against forum shopping requirement.

RULING

Yes. The Supreme Court reversed the Court of Appeals and ordered the dismissal of Civil Case No. 12194. The certification against forum shopping is a mandatory requirement, and a willful and deliberate violation of this rule warrants the dismissal of the case. The Court found that respondents’ certification was fatally defective. At the time they filed the new complaint in 2001, their petition in G.R. No. 143492—which originated from their first case (Civil Case No. 10265) involving the same property and the same cause of action for annulment of the sales—was still pending before the Supreme Court. Their failure to disclose this pending action in their certification constituted forum shopping. The fact that the complaint itself mentioned the prior case did not cure the defect in the certification, which must be complete and accurate on its face. The rule against forum shopping is designed to prevent the vexatious practice of filing multiple suits to increase the chances of a favorable ruling, and its violation justifies the dismissal of the case without prejudice to any other sanctions. Consequently, the Supreme Court reinstated the trial court’s original order dismissing the complaint.