G.R. No. 72200 . March 30, 1993.
SANPIRO FINANCE CORPORATION, petitioner, vs. INTERMEDIATE APPELLATE COURT, LAGUNA TRANSPORTATION CO. INC., AND LAURO LOPEZ DE LEON, respondents.

FACTS

Private respondents Laguna Transportation Co. Inc. and Lauro Lopez de Leon purchased diesel buses from Delta Motor Corp. (Delta), executing promissory notes and deeds of chattel mortgage. On February 27, 1981, Delta executed a Deed of Assignment in favor of the Philippine National Bank (PNB) as security for credit accommodations. Later, on January 6 and 9, 1984, Delta executed two Deeds of Assignment in favor of petitioner Sanpiro Finance Corporation covering the same debts of private respondents. Consequently, both PNB and Sanpiro demanded payment from private respondents for the same obligations. Faced with conflicting claims, private respondents filed an interpleader complaint (Civil Case No. 2146) on October 1, 1984, in the Regional Trial Court (RTC) of Laguna against Sanpiro, PNB, and Delta to determine who is entitled to payment. On October 4, 1984, Sanpiro filed a complaint for replevin with damages (Civil Case No. 8636) in the RTC of Makati against private respondents, Delta, and others. On October 5, 1984, the Makati RTC issued a writ of seizure, leading to the taking of six of private respondents’ buses. Despite knowledge of the pending Laguna interpleader case, the Makati court denied private respondents’ motions to dismiss and discharge the writ, and ordered the surrender of the remaining buses. Private respondents then filed a petition for certiorari with the Intermediate Appellate Court, which annulled the Makati court’s orders and writs, and ordered the return of the seized buses. Sanpiro elevated the case to the Supreme Court.

ISSUE

Whether the Intermediate Appellate Court correctly annulled the orders and writs issued by the Makati RTC in Civil Case No. 8636 on the ground of litis pendentia (lis pendens).

RULING

Yes, the Intermediate Appellate Court correctly annulled the orders and writs. The Supreme Court found that the requisites of lis pendens were present: (1) identity of parties, as Sanpiro, Laguna Trans, de Leon, and Delta were parties in both the Laguna and Makati cases, and the addition or elimination of other parties (PNB, Mauro Vera Cruz, Francisco Magante) does not alter this identity; (2) identity of rights asserted and reliefs prayed for, as both cases sprang from the Deeds of Assignment executed by Delta covering the same debts of private respondents, and both sought payment of these same debts; and (3) the identity is such that a judgment in the pending Laguna case would amount to res judicata in the Makati case. Specifically, if the Laguna court rules that the assignment to PNB prevails, that judgment would bind the Makati case and render Sanpiro’s cause of action baseless. Therefore, the Makati court acted with precipitate haste, imprudence, and lack of judicial caution, amounting to grave abuse of discretion, in ordering the seizure of the buses despite full cognizance of the pending Laguna case. The petition was denied.