GR 216139; (November, 2017) (Digest)
G.R. No. 216139 November 29, 2017
BERNARDO S. ZAMORA, Petitioner vs. EMMANUEL Z. QUINAN, JR., EMMANUEL J. QUINAN, SR., EFREM Z. QUINAN and EMMA ROSE Q. QUIMBO, Respondents
FACTS
Petitioner Bernardo S. Zamora filed a Complaint for Reconveyance of Title before the Regional Trial Court (RTC) of Cebu City, Branch 19, docketed as Civil Case No. CEB-32448. This action sought to recover real properties, claiming he possessed the original Transfer Certificates of Title. The titles had been the subject of a Petition for Issuance of New Duplicate Certificate of Title earlier granted to respondents by the RTC of Cebu City, Branch 9.
While his reconveyance case was pending, petitioner initiated a separate Petition for Annulment of Judgment before the Court of Appeals (CA), seeking to nullify the RTC Branch 9 order that granted the new titles to respondents. This petition was dismissed on technicalities. Petitioner then filed a second annulment petition with the CA. Subsequently, the RTC Branch 19 dismissed his reconveyance complaint on the ground of forum shopping. Respondents then moved to dismiss the second annulment petition before the CA on the same ground, which the CA granted.
ISSUE
Whether the Court of Appeals correctly dismissed the Petition for Annulment of Judgment on the ground of forum shopping.
RULING
Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed that petitioner committed willful and deliberate forum shopping. Forum shopping exists when a party institutes two or more actions in different courts, simultaneously or successively, to obtain a favorable judgment based on identical causes of action, subject matter, and essential parties and reliefs.
The legal logic is grounded on the principle that these multiple actions constitute an abuse of judicial process, undermining the orderly administration of justice by burdening the courts and potentially leading to conflicting rulings. In this case, the Court found identity of parties (petitioner versus respondents), reliefs (both ultimately aimed at establishing petitioner’s ownership and invalidating respondents’ titles), and causes of action (both rooted in the alleged impropriety of the RTC Branch 9’s order for reconstitution and issuance of new titles). The filing of the annulment case while the reconveyance suit was pending, and the subsequent filing of a second annulment petition, clearly demonstrates a strategy to seek the same objective in different fora. The Court emphasized that procedural rules against forum shopping are strictly applied to prevent such abuses. Petitioner’s invocation of substantive arguments regarding the validity of the reconstituted titles was deemed irrelevant to the separate, dispositive issue of his procedural transgression.