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SANTOS VENTURA HOCORMA FOUNDATION v. MABALACAT INSTITUTE

FACTS:

The Santos Ventura Hocorma Foundation, Inc. (SVHFI) claimed ownership of a parcel of land occupied by Mabalacat Institute, Inc. (MII) without paying rent. SVHFI informed MII about the rental charges, but MII refused to comply. SVHFI filed a collection case against MII in the Regional Trial Court (RTC) of Makati City. MII filed a motion to dismiss on the ground of lack of valid service of summons, but the motion was denied. MII appealed the denial to the Court of Appeals (CA), but the appeal was denied. SVHFI then filed an ejectment case against MII in the Municipal Circuit Trial Court (MCTC) of Mabalacat and Magalang, Pampanga. The RTC granted MII's motion to dismiss the collection case, finding SVHFI guilty of forum shopping. SVHFI appealed to the CA, but its appeal was denied. SVHFI and MII both filed petitions for review on certiorari with the Supreme Court. The Supreme Court denied MII's petition, ruling that the fate of MII's counterclaim should be decided by the RTC. The issue in the case is whether SVHFI committed forum shopping.

ISSUES:

  1. Whether or not there is forum shopping committed by the petitioner.

  2. Whether the damages that can be recovered in ejectment cases are limited only to those which the plaintiff could have sustained as a mere possessor or those caused by the loss of use and occupation of the property.

  3. Whether a judgment rendered in an ejectment case will amount to res judicata in a civil case for the collection of a sum of money for unpaid rent of the same property and vice versa.

  4. Whether the filing of an ejectment case subsequent to a collection case, while the latter is still pending, constitutes forum shopping.

  5. Whether there is an identity of rights asserted and reliefs prayed for in the ejectment case and the collection case.

  6. Whether any judgment on the ejectment case would amount to res judicata on the collection case.

RULING:

  1. The Supreme Court held that the petitioner did not commit forum shopping.

  2. The damages that can be recovered in ejectment cases are limited only to those which the plaintiff could have sustained as a mere possessor or those caused by the loss of use and occupation of the property. The damages that can be recovered are directly related to the loss of material possession and not those that have no direct relation to the loss of possession.

  3. A judgment rendered in an ejectment case will not amount to res judicata in a civil case for the collection of a sum of money for unpaid rent of the same property and vice versa. The causes of action are different, and the recovery of damages for loss of possession in an ejectment case does not bar the recovery of unpaid rent in a collection case.

  4. The Court held that the filing of an ejectment case subsequent to a collection case, while the latter is still pending, does not constitute forum shopping. The Court emphasized that there is no identity of rights asserted and reliefs prayed for in both cases, and that a judgment on one case would not amount to res judicata on the other.

  5. The Court found that there is no identity of rights asserted and reliefs prayed for in the ejectment case and the collection case. The ejectment case is based on the prejudice suffered due to the loss of possession, while the collection case is founded on the appropriate amount of rental fees and damages suffered unrelated to the loss of possession.

  6. The Court ruled that any judgment on the ejectment case would not amount to res judicata on the collection case. The causes of action and reliefs sought in both cases are different, and the determination of one case does not have a direct impact on the other.

PRINCIPLES:

  • Forum shopping is the practice of resorting to multiple fora for the same relief in order to increase the chances of obtaining a favorable judgment. It is prohibited under Section 5, Rule 7 of the Rules of Court. The elements of forum shopping are: (i) identity of parties, (ii) identity of rights asserted and relief prayed for, and (iii) any judgment rendered in one action will amount to res judicata in the other action.

  • Litis pendentia exists when the elements of forum shopping are present, or whether a final judgment in one case will amount to res judicata in another. The requisites of litis pendentia are: (a) the identity of parties or parties representing the same interests, (b) the identity of rights asserted and relief prayed for, and (c) the identity of the two cases such that judgment in one would amount to res judicata in the other.

  • In an ejectment proceeding, the only issue to be settled is physical possession of the property. On the other hand, in a collection case, the purpose is to compel the defendant to pay rent. The claims in the collection case do not have a direct relation to the loss of material possession of the subject property in the ejectment case.

  • In ejectment cases, the damages that can be recovered are limited to those which the plaintiff could have sustained as a mere possessor or those caused by the loss of use and occupation of the property.

  • A judgment rendered in an ejectment case does not amount to res judicata in a civil case for the collection of a sum of money for unpaid rent of the same property and vice versa.

  • Joinder of causes of action in a single pleading is prohibited, particularly the joinder of an ordinary action, such as an action for the collection of a sum of money, and a special civil action, such as an ejectment suit.

  • Forum shopping is the act of a party who repetitively avails of multiple judicial remedies in different forums, either simultaneously or successively, to increase the chances of success or to avoid adverse decisions. The elements of forum shopping are (a) identity of parties, or at least such parties as represent the same interest in both actions; (b) identity of rights asserted and reliefs prayed for, the reliefs being founded on the same facts; and (c) identity with respect to the two preceding particulars in the two cases, such that any judgment rendered in the other action will, regardless of which party is successful, amount to res judicata in the action under consideration.

  • Res judicata refers to the rule that a final judgment on the merits rendered by a court of competent jurisdiction is conclusive as to the rights of the parties and their privies, and constitutes an absolute bar to a subsequent action involving the same claim, demand, or cause of action. The requisites for res judicata to apply are (a) the former judgment or order must be final; (b) the former judgment or order must be one on the merits; (c) the parties, or those in privity with them, must be the same in both actions; and (d) there must be identity between the two cases insofar as the parties, subject matter, and causes of action are concerned.