GR 184015; (February, 2012) (Digest)
G.R. No. 184015 ; February 8, 2012
SPOUSES MARIANO P. MARASIGAN and JOSEFINA LEAL, Petitioners, vs. CHEVRON PHILS., INC., ACCRA INVESTMENTS, CORP., and ANGARA ABELLO CONCEPCION REGALA & CRUZ, Respondents.
FACTS
Petitioners Spouses Marasigan, operators of a gasoline station, entered into a dealership agreement with respondent Chevron Phils., Inc. They executed real estate mortgages over several properties to secure credit lines. Upon default, Chevron extrajudicially foreclosed the mortgages. One property, a 167-hectare coconut farm in Mulanay, Quezon, was sold at auction for only ₱130,000 to ACCRA Investments Corp., a bid the spouses alleged was grossly inadequate. Chevron then filed a collection case (Civil Case No. 95-1619) before the RTC of Makati to recover the deficiency balance after the foreclosure.
Subsequently, the spouses filed a separate complaint (Civil Case No. 2448-G) before the RTC of Gumaca, Quezon, seeking the annulment of the foreclosure sale of the Mulanay property, primarily on the ground of gross inadequacy of price. The respondents moved to dismiss this second case on the grounds of forum shopping and litis pendentia, arguing the Makati case was pending and involved the same core issue.
ISSUE
Whether the complaint filed before the RTC-Gumaca is dismissible on the grounds of forum shopping and litis pendentia.
RULING
Yes, the Court of Appeals correctly dismissed the Gumaca case. All elements of litis pendentia are present: (1) identity of parties, or at least such parties as represent the same interests in both actions; (2) identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (3) identity of the two cases such that a judgment in one would constitute res judicata in the other. The parties in the two cases are substantially the same, with Chevron and the Spouses Marasigan as the principal adversaries. The rights asserted and the reliefs arise from the same series of transactions—the foreclosure and the resulting deficiency claim. The defense of an invalid foreclosure due to gross inadequacy of price, raised in the Makati case, is the very cause of action in the Gumaca case. A ruling in either case on the validity of the foreclosure sale would be conclusive in the other. Therefore, the later-filed Gumaca case constitutes forum shopping and must be dismissed in favor of the prior pending Makati action, which is the proper vehicle to litigate all related issues. The petition is denied.