G.R. No. 210592 November 22, 2017
REGINO DELA CRUZ, substituted by his heirs, Petitioners, vs. IRENEO DOMINGO, et al., Respondents.

FACTS

Respondent Ireneo Domingo is the registered owner of a parcel of land in Nueva Ecija, covered by Transfer Certificates of Title (TCTs) issued in 1989. Petitioner Regino Dela Cruz claimed to be a farmer-beneficiary of portions of the same land, holding a Certificate of Land Transfer (CLT). Domingo filed three separate DARAB cases for recovery of possession against Dela Cruz, resulting in a consolidated decision ordering Dela Cruz to vacate. While his motion for reconsideration in those cases was pending, Dela Cruz initiated a new DARAB case (No. 372) seeking annulment of Domingo’s titles, alleging prior sale of the land to him and that Domingo’s emancipation patents were obtained through fraud and that Domingo was disqualified as a beneficiary due to physical disability.
The Provincial Adjudicator dismissed DARAB Case No. 372, finding Dela Cruz’s evidence insufficient to prove the alleged sale or fraud. The DARAB affirmed the dismissal on appeal, noting the CLT referred to a landholding in a different barangay and upholding the presumption of regularity in the issuance of Domingo’s titles. Dela Cruz elevated the matter to the Court of Appeals via a Petition for Review.

ISSUE

Whether the Court of Appeals correctly dismissed the Petition for Review on the ground of forum shopping.

RULING

Yes, the Court of Appeals correctly dismissed the petition. Forum shopping exists when a party, seeking the same relief, institutes two or more actions in different courts or tribunals based on the same cause of action. Here, Dela Cruz’s filing of DARAB Case No. 372 for annulment of title while his motion for reconsideration in the earlier recovery of possession cases (DARAB Case Nos. 298-300) was still pending constitutes forum shopping. The cause of action in both sets of cases fundamentally relates to the ownership and possession of the same landholding. By initiating the second case, Dela Cruz attempted to secure a favorable ruling from a different adjudicator on the same substantive issue, which is precisely the mischief that the rule against forum shopping seeks to prevent. The Supreme Court affirmed the dismissal, emphasizing that such procedural infirmity warrants the outright rejection of the petition without need to delve into the substantive merits. The Court further noted that the DARAB, as the specialized agency, had already thoroughly examined and rejected Dela Cruz’s claims of ownership and fraud on substantive grounds, finding his evidence inadequate to overcome Domingo’s registered titles.