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CHRISTINE CHUA v. JORGE TORRES

FACTS:

On 24 October 2001, a complaint for damages was filed by Christine Chua against Jorge Torres and Antonio Beltran before the Regional Trial Court (RTC) of Caloocan City. The complaint alleged that Jonathan Chua, the brother of Christine, issued a check in favor of the 9th Avenue Caltex Service Center in payment for purchases of diesel oil. The check was dishonored and petitioner was informed of the dishonor. Beltran, an employee of the service center, then instituted a criminal action for violation of Batas Pambansa Bilang 22 (B.P. 22) against petitioner. Petitioner claimed that Beltran's action amounted to malicious prosecution or serious defamation. The complaint sought damages and named Jonathan Chua as a necessary party-plaintiff, although Jonathan did not allege any injury or sign any verification or certification against forum-shopping. The RTC dismissed the complaint for failure to comply with the mandatory requirement of the certification against forum-shopping. Petitioner filed a petition for review, arguing that Jonathan Chua, as a necessary party-plaintiff, should not be required to sign the certification against forum-shopping.

ISSUES:

  1. Whether the absence of the signature in the required verification and certification against forum-shopping of a party misjoined as a plaintiff is a valid ground for the dismissal of the complaint.

RULING:

  1. No, the absence of the signature in the required verification and certification against forum-shopping of a party misjoined as a plaintiff is not a valid ground for the dismissal of the complaint. The court ruled that a misjoined party plaintiff should not be required to comply with all the requirements expected of plaintiffs, and that any act or omission committed by a misjoined party plaintiff should not impede the prosecution of the case. Misjoinder of parties is not fatal to the complaint, and such parties can be dropped by the court at any stage of the action.

PRINCIPLES:

  1. Misjoinder of Parties: Neither misjoinder nor non-joinder of parties is a ground for the dismissal of an action (Section 11, Rule 3 of the 1997 Rules of Civil Procedure).

  2. Real Party in Interest: A civil suit may be prosecuted only in the name of the real party in interest (Section 2, Rule 3 of the Rules of Civil Procedure).

  3. Verification Requirement: Intended to ensure that allegations in the pleading are true, correct, and filed in good faith.

  4. Certification Against Forum-Shopping: Required to ensure that a plaintiff does not file multiple cases with the same cause of action, but not required for misjoined parties.

  5. Judicial Discretion: Courts can drop misjoined parties on their own initiative at any stage of the action to correct errors without dismissing the case.