G.R. No. 84750. May 16, 1989.
BULIG-BULIG KITA KAMAG-ANAK ASSOCIATION, ET AL., petitioners, vs. SULPICIO LINES, INC. and REGIONAL TRIAL COURT, ETC., respondents.

FACTS

The petitioners, representing numerous claimants arising from the Doña Paz maritime disaster, sought a writ of certiorari to nullify a Regional Trial Court (RTC) Order dated June 29, 1988. The RTC, citing the Supreme Court’s Resolution dated March 3, 1988 in Administrative Matter No. 88-1-646-0, ruled that the claimants could not maintain a class suit under Section 12, Rule 3 of the Rules of Court. Instead, the court directed them to proceed under the rule on permissive joinder of parties under Section 6, Rule 3, and required compliance with filing fee or pauper litigant requirements within thirty days.
The petitioners challenged the RTC Order, arguing that the Supreme Court’s March 3, 1988 Resolution was merely advisory, having been issued in response to a mere letter-request from counsel. They contended that forcing individual suits would cause a flood of litigation. They proposed a two-stage process: a class suit to first establish the carrier’s general liability for negligence, followed by individual suits to determine specific damages.

ISSUE

Whether the respondent RTC committed grave abuse of discretion in upholding the Supreme Court’s March 3, 1988 Resolution and ruling that a class suit was improper, requiring the claimants to proceed via joinder of parties.

RULING

The Supreme Court DISMISSED the petition for lack of merit, finding no grave abuse of discretion by the RTC. The Court held that its March 3, 1988 Resolution constituted binding precedent. It was not a mere advisory opinion but an authoritative adjudication of a concrete, substantive issue in a pending litigation, necessary to govern the case’s proceedings and prevent delay.
The Court rejected the petitioners’ claim that the Resolution compelled separate suits, clarifying that it expressly permitted joinder of all claimants in a single proceeding under Section 6, Rule 3. The petitioners’ proposed two-stage class suit was procedurally improper and would ironically create the very “flood of litigation” they sought to avoid, as it would necessitate numerous follow-up cases. The Court noted that whether via class suit or joinder, the pleading requirements and total filing fees (based on the aggregate claims) would be substantially the same, as individual circumstances and damages would differ per claimant.
The Court further addressed the pauper litigant issue, stating that only four of the twelve petitioners submitted the required sworn statements of indigency. Compliance with the alternative requirements of Section 22, Rule 3 was straightforward, and those with means could not be exempted from fees. Finally, the Court suggested that procedural mechanisms like consolidation of actions under Rule 31 offered practical solutions for managing multiple suits arising from a single event, within the sound discretion of the courts involved.