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PHILIPPINE NATIONAL BANK v. DE GUZMAN

FACTS:

Philippine National Bank (PNB) filed a petition for review on certiorari against the Intestate Estate of Francisco de Guzman and his heirs. The respondents had obtained a loan from PNB, secured by a real estate mortgage. A complaint was initially filed by Rosalia, alleging the fraudulent sale of the property. However, the case was dismissed by the Regional Trial Court (RTC) due to non-compliance with an order to pay legal fees, and no appeal was made, making the dismissal final and executory. The Intestate Estate later filed a similar complaint, which PNB sought to dismiss based on res judicata and forum shopping. Multiple motions to dismiss were denied by the RTC. PNB then filed an omnibus motion for reconsideration, asserting other grounds such as lack of jurisdiction and absence of cause of action. The omnibus motion was denied, and PNB was ordered to file its answer. PNB filed an answer to the complaint, once again raising the issue of res judicata. After three years, PNB filed another motion to dismiss on the basis of res judicata and forum shopping, which was also denied by the RTC. Furthermore, the RTC disallowed any further motions to dismiss.

ISSUES:

  1. Whether or not the filing of the second complaint is barred by res judicata.

  2. Whether or not the filing of the second complaint constitutes forum shopping.

RULING:

  1. The Supreme Court held that since there was no determination of the merits of the first case, the filing of the second complaint is not barred by res judicata. The dismissal of the first case due to the plaintiff's failure to comply with the court's order to pay the legal fees did not constitute a decision on the merits of the case and cannot be considered as a judgment on the validity of the claims.

  2. The Supreme Court ruled that the filing of the second complaint does not constitute forum shopping. Forum shopping exists if a final judgment in one case would amount to res judicata in another case. Since the court had already ruled that the dismissal of the first complaint did not constitute res judicata, the respondents were not guilty of forum shopping.

PRINCIPLES:

  • Litigants should not be allowed to file identical motions repeatedly, speculating on the possible change of opinion of the court or its judges.

  • The filing of a second complaint is not barred by res judicata if there was no determination of the merits of the first case.

  • Forum shopping exists if a final judgment in one case would amount to res judicata in another case.