GR 84750; (May, 1989) (Digest)
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 from the Doña Paz maritime disaster, sought certiorari to nullify a Regional Trial Court Order dated June 29, 1988. That Order, citing this Supreme Court’s Resolution of 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, but could join in one action under the permissive joinder rule (Section 6, Rule 3). The Order also required them to comply with filing fee or pauper litigant requirements within thirty days.
ISSUE
Whether the respondent court committed grave abuse of discretion in issuing the challenged Order, particularly in relying on the Supreme Court’s March 3, 1988 Resolution and denying the petitioners’ right to institute a class action.
RULING
The Supreme Court DISMISSED the petition for lack of merit, finding no grave abuse of discretion by the respondent court. The Court upheld its March 3, 1988 Resolution as a binding precedent, rejecting the petitioners’ claim that it was merely advisory. The Resolution authoritatively settled a concrete procedural issue arising from actual litigation to prevent delay. The Court clarified that the Resolution did not compel thousands of separate suits; it explicitly permitted joinder of parties in a single proceeding under Section 6, Rule 3.
The petitioners’ proposed two-stage litigation—a class suit to establish general liability for negligence, followed by individual suits to determine specific damages—was proscribed by procedural rules and would ironically cause the very “flood of litigation” they sought to avoid. The Court found no substantive difference in the paperwork or filing fees between a proper class suit and a joinder-of-parties action, as the totality of claims determines fees and individual circumstances must still be pleaded. Regarding pauper status, the Court noted that only four of twelve petitioners submitted the required sworn statements, and compliance with the alternative proofs under Section 22, Rule 3 was not unduly burdensome. The Court concluded that a class suit was improper for the reasons stated in the March 3, 1988 Resolution and advised the petitioners to avail of joinder of parties or, to address concerns about multiple cases, the consolidation mechanisms under Rule 31, which courts can adopt to efficiently try numerous actions stemming from a single event.