GR 73592; (March, 1996) (Digest)
G.R. No. 73592 March 15, 1996
JOSE CUENCO BORROMEO, PETRA BORROMEO and VITALIANA BORROMEO, petitioners, vs. HON. INTERMEDIATE APPELLATE COURT, HON. FRANCISCO P. BURGOS, RICARDO V. REYES, DOMINGO ANTIGUA and NUMERIANO G. ESTENZO, respondents.
FACTS
This case arose from Special Proceedings No. 916-R for the settlement of the estate of Vito Borromeo. The probate court, in 1969, approved a project of partition, and transfer certificates of title were subsequently issued to the heirs in 1970-1971. Years later, in 1982, the probate court, presided by Judge Francisco P. Burgos, ordered the cancellation of these titles and the reversion of the properties to the estate. Petitioners, who are heirs, had previously sought the disqualification of Judge Burgos on grounds of bias, which the Intermediate Appellate Court (IAC) granted in a 1983 decision. Despite this disqualification, Judge Burgos continued to act on the case.
Petitioners filed multiple actions challenging Judge Burgos’s authority and his subsequent orders. They appealed the IAC’s disqualification decision to the Supreme Court in G.R. No. 63818. They also filed a separate petition with the Supreme Court in G.R. No. 65995 to stop Judge Burgos from further hearing the case. Concurrently, they filed a petition with the IAC in AC-G.R. SP No. 03409, assailing the validity of Judge Burgos’s 1984 order cancelling the titles.
ISSUE
Whether the petitioners committed forum-shopping by filing multiple petitions in different courts involving the same core issues and seeking similar reliefs.
RULING
Yes, the Supreme Court affirmed the IAC’s finding that petitioners were guilty of forum-shopping. The legal logic is that forum-shopping exists when a party, seeking the same or substantially similar relief, institutes two or more actions in different courts based on the same cause. The Court examined the three related cases filed by petitioners. G.R. No. 63818 sought affirmance of the IAC’s decision disqualifying Judge Burgos. G.R. No. 65995 sought to restrain and invalidate all acts of Judge Burgos after his disqualification. AC-G.R. SP No. 03409, the petition before the IAC, assailed the specific order issued by the disqualified judge. The Court found that these petitions involved intimately related causes and sought essentially the same objective: to nullify the proceedings and orders issued by Judge Burgos after he had been disqualified. This constituted a clear violation of the rule against forum-shopping, which is condemned as a reprehensible manipulation of court processes that burdens the judiciary and creates the risk of conflicting decisions. The IAC correctly dismissed AC-G.R. SP No. 03409 on this ground.