FACTS:

Petitioner sold a parcel of land to the government for expropriation in 1978. The sale was subject to reconveyance of any unused portion after the construction project is completed. In 1988, petitioner entered into a "Contract to Sell" with respondent, but failed to comply with his obligations under the contract. Respondent filed a complaint for rescission/annulment of the contract, which resulted in a compromise agreement approved by the court. Pursuant to the compromise judgment, petitioner executed a deed of absolute sale in favor of respondent. A separate agreement was also executed regarding the unused portion of the land sold to the government. Meanwhile, petitioner sought the reconveyance of the unused portion from the government and was granted such by the Office of the President. Respondent filed a petition before the RTC seeking to declare the reconveyance void and to order the Office of the President to allow respondent to purchase the land. The RTC dismissed the case for lack of merit. Respondent then filed an action for specific performance based on the compromise judgment. Petitioner filed a motion to dismiss and for direct contempt based on forum shopping. The Court of Appeals granted respondent's motion to withdraw the petition before it and dismissed the case. However, the RTC denied petitioner's motion to dismiss and for direct contempt, stating that there was no violation of Supreme Court Circular No. 04-94 and that the two cases did not have the same causes of action. Petitioner filed a motion for reconsideration, which was denied. Thus, this petition for certiorari was filed.

ISSUES:

1. Whether or not petitioner engaged in forum shopping

2. Whether or not the two cases have the same causes of action

RULING:

1. The Court of Appeals and the Regional Trial Court both denied the motion to dismiss based on forum shopping. The Court of Appeals held that the alleged violation of Supreme Court Circular No. 04-94 was cured when CA-G.R. SP No. 44094 was dismissed with finality. The Regional Trial Court, on the other hand, held that petitioner failed to show that the two cases have the same causes of action.

PRINCIPLES:

• Forum shopping is prohibited and is deemed a violation of the principle of integrity of judicial processes.

• In order for forum shopping to exist, there must be identity of (a) parties, or at least such parties that represent the same interest in both actions, (b) rights or causes of action, and (c) reliefs sought.