G.R. No. L-45107 November 11, 1991
BENEDICTO RAMOS, petitioner, vs. HON. ELVIRO L. PERALTA, Presiding Judge, Branch XVII, Court of First Instance of Manila, SPOUSES JUVENCIO ORTANEZ and JULIANA S. ORTANEZ, MINDANAO INSURANCE CO., INC. and P. R. ROMAN, INC., respondents.

FACTS

Petitioner Benedicto Ramos leased a fishpond in Bataan from spouses Juvencio and Juliana Ortanez under a contract renewed several times, the last being a “Kasunduan sa Pag-upa” effective from January 1, 1975 to December 31, 1977. Unknown to Ramos, the property’s title was in the name of Mindanao Insurance Co., Inc., a corporation placed under receivership. On February 23, 1976, respondent P. R. Roman, Inc. purchased the fishpond from the receiver. Consequently, the Ortanez spouses refused Ramos’s tender of advance rentals due on March 15 and June 15, 1976, totaling P70,000. P. R. Roman, Inc. also informed Ramos of its acquisition and took possession of the property.
On August 2, 1976, Ramos filed a consignation case (Civil Case No. 103647) before the CFI of Manila against the Ortanez spouses, Mindanao Insurance, and P. R. Roman, Inc., seeking to deposit the refused rentals. P. R. Roman, Inc. moved to dismiss, citing the pendency of Civil Case No. 4102, an action to quiet title it had filed against Ramos on August 13, 1976, before the CFI of Bataan. The Manila CFI dismissed the consignation case, ruling that all issues regarding the fishpond, including the lease, were necessarily involved in the Bataan case.

ISSUE

Whether the Court of First Instance of Manila correctly dismissed the consignation case on the ground of litis pendentia due to the pending quieting of title case in Bataan.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed the lower court’s order, holding that the principle of litis pendentia warranted the dismissal of the Manila consignation case. For litis pendentia to apply, there must be identity of parties, identity of rights asserted and relief prayed for, and identity in the two cases such that any judgment in one would constitute res judicata in the other. While the consignation action formally concerned the refusal to accept rental payment, its resolution was fundamentally dependent on the validity of Ramos’s leasehold rights, which was the core issue in the Bataan quieting of title suit filed by P. R. Roman, Inc. A judgment in the Bataan case declaring P. R. Roman, Inc. as the absolute owner could extinguish the lease, thereby negating any obligation to pay rentals to the Ortanez spouses. Thus, the cases involved substantially the same fundamental issue.
The Court further ruled that the plaintiff’s prerogative to choose venue must yield to the greater interest of orderly administration of justice to avoid the possibility of conflicting decisions. The fact that the consignation case was filed earlier did not preclude the application of litis pendentia, as the rule requires merely a pending action, not necessarily a prior pending one. Given the broader scope of the Bataan case and the property’s location, the Manila court correctly deferred to the Bataan court’s jurisdiction.