GR 182151; (September, 2015) (Digest)
G.R. No. 182151 , September 21, 2015
IGLICERIA VDA. DE KARAAN, Petitioner, vs. ATTY. SALVADOR AGUINALDO, MARCELINA AGUINALDO, JUANITA AGUINALDO AND SERGIO AGUINALDO, Respondents.
FACTS
Petitioner Igliceria vda. de Karaan filed a Complaint for damages against respondents before the Regional Trial Court (RTC) of Quezon City (Civil Case No. Q-99-38762). She alleged that respondents unlawfully destroyed structures inside her Fine Sand Beach Resort using a bulldozer, under the guise of enforcing a Writ of Demolition from the RTC of Balanga in unrelated civil cases where she was not a party. Respondents moved to dismiss the complaint on grounds of forum shopping, claiming petitioner failed to disclose other actions she had filed against them, including cases before the Office of the Ombudsman and the Integrated Bar of the Philippines, and Civil Case No. 7345 (a right-of-way case in Balanga, Bataan). The RTC denied the motion. Respondents then filed a Petition for Certiorari with the Court of Appeals (CA), which granted it, finding petitioner guilty of forum shopping due to the pendency of Civil Case No. 7345, which involved identical parties and a claim for damages arising from the same demolition. The CA ordered the dismissal of Civil Case No. Q-99-38762. Petitioner sought reconsideration, which was denied, leading to this Petition for Review.
ISSUE
Whether the filing of Civil Case No. 7345 constituted forum shopping on the part of petitioner.
RULING
The Supreme Court GRANTED the Petition, reversing the CA’s decision. The Court held that petitioner was not guilty of forum shopping. While there was identity of parties between Civil Case No. Q-99-38762 and Civil Case No. 7345 (as petitioner’s name appeared as a plaintiff in the latter), there was no substantial identity in the causes of action and reliefs sought. Civil Case No. 7345 was primarily a right-of-way action under Article 649 of the Civil Code, with a claim for damages incidental to the closure of a road. In contrast, Civil Case No. Q-99-38762 was a direct action for damages based on the alleged malicious and unlawful demolition of resort structures. The causes of action differed in essential facts and evidence required. Thus, the elements of litis pendentia—specifically, substantial identity in causes of action and reliefs—were not present. The Court emphasized that forum shopping requires multiple suits involving the same parties and same causes of action, which was not established here.