GR 186720; (February, 2012) (Digest)
G.R. No. 186720; February 8, 2012
ELSA D. MEDADO, Petitioner, vs. HEIRS OF THE LATE ANTONIO CONSING, as represented by DR. SOLEDAD CONSING, Respondents.
FACTS
In 1996, petitioner Elsa Medado and her husband (Spouses Medado) acquired Hacienda Sol from the Estate of Antonio Consing through Deeds of Sale with Assumption of Mortgage. The Spouses Medado undertook to assume the estate’s loan with PNB. Subsequently, the Estate of Consing offered the same properties for sale to the government under the DAR’s Voluntary Offer to Sell (VOS) program. The Estate also filed an action for rescission of the deeds of sale (Civil Case No. 00-11320) against the spouses in the RTC of Bacolod City, alleging failure to meet the agreement’s conditions.
While the rescission case was pending, Land Bank issued a certificate of deposit for the VOS compensation in favor of the Estate. Fearing the release of these proceeds to the Estate, the Spouses Medado filed a separate action for injunction (Civil Case No. 797-C) in the RTC of Cadiz City. They sought to restrain Land Bank from releasing, and the Estate from receiving, the VOS proceeds, and to compel Land Bank to release the proceeds to them instead. The Cadiz RTC granted the application for preliminary prohibitory and mandatory injunction.
ISSUE
Whether the Court of Appeals correctly nullified the RTC Cadiz City’s order and dismissed the injunction case on the grounds of litis pendentia and forum shopping.
RULING
Yes, the Supreme Court affirmed the Court of Appeals’ decision. The legal logic is anchored on the prohibition against forum shopping and the principle of litis pendentia. Forum shopping exists when a party, seeking a more favorable ruling, institutes two or more actions in different courts based on the same cause and involving the same essential parties and issues. Litis pendentia requires the concurrence of identity of parties, rights asserted, and reliefs sought between the pending and subsequent cases.
Here, both the rescission case in Bacolod and the injunction case in Cadiz involved the same fundamental controversy: the rights and obligations of the Spouses Medado and the Estate of Consing arising from the Deeds of Sale with Assumption of Mortgage concerning Hacienda Sol. The relief sought in the injunction case—control over the VOS proceeds—was intrinsically connected to and dependent upon the resolution of the issue of ownership and validity of the sale, which was the very subject of the pending rescission case. By filing the injunction suit, the Spouses Medado effectively split their cause of action and sought a remedy that would preempt the outcome of the prior pending case. This constituted forum shopping and warranted the dismissal of the later-filed injunction case to prevent multiplicity of suits and avoid the possibility of conflicting judgments.