Case Digest (G.R. No. 221781)
Facts:
The case involves ABS-CBN Corporation (Petitioner) and Willie B. Revillame (Respondent) in a series of legal disputes stemming from their contractual relationship. On September 11, 2008, ABS-CBN and Revillame executed an agreement which stipulated that Revillame would host a show titled "Wowowee" from September 11, 2008, to September 10, 2011, unless terminated earlier for specified reasons. Approximately one and a half years into the agreement, tensions escalated when Revillame requested that ABS-CBN terminate the employment of Jobert Sucaldito, a co-host he considered an adversary, threatening to resign if his demand was unmet. In response to ABS-CBN’s refusal, Revillame abstained from hosting the show from May 5 to May 24, 2010, later requesting his release from the talent agreement. ABS-CBN suspended Revillame instead, issuing a three-month suspension without pay.
Subsequently, on July 26, 2010, ABS-CBN informed Revillame that "Wowowee" would be replaced
Case Digest (G.R. No. 221781)
Facts:
- Consolidated Petitions and Parties
- Three separate petitions were consolidated before the Court:
- G.R. No. 221781 – Filed by ABS‑CBN Corporation challenging the CA’s dismissal of its Rule 65 petition against Willie B. Revillame.
- G.R. No. 225095 – Also filed by ABS‑CBN Corporation assailing the CA’s dismissal of its Rule 65 petition related to the examination of the AIPC Bond and alleged grave abuse of discretion of the RTC-Quezon City, Branch 217.
- G.R. No. 236167 – Filed by Revillame challenging the reinstatement by the CA of ABS‑CBN’s compulsory counterclaims in Civil Case No. Q‑10‑67770.
- The parties involved are ABS‑CBN Corporation, Willie B. Revillame, and ABC Development Corporation among others.
- Underlying Contractual Relationship and Early Dispute
- On September 11, 2008, ABS‑CBN and Revillame entered into an Agreement for Revillame to host a show entitled “Wowowee” for three years or until cancellation/early termination under stipulated conditions.
- A dispute arose about a year and a half into the Agreement:
- During a live episode on May 4, 2010, Revillame demanded the dismissal of a co‑host, Jobert Sucaldito, and threatened to resign if his demand was not met.
- Upon ABS‑CBN’s refusal, Revillame stopped hosting the show temporarily and subsequently requested his release as talent.
- ABS‑CBN countered by suspending him for three months without pay and later offering him a one‑hour weekly replacement show.
- Revillame, dissatisfied with the offer, declared on August 9, 2010 his decision to rescind the Agreement on grounds of breach by ABS‑CBN.
- Initiation of Litigations and Corresponding Proceedings
- Following the rescission, on August 23, 2010, Revillame initiated a civil action (Civil Case No. Q‑10‑67770) seeking judicial confirmation of rescission and claimed damages, including moral and exemplary damages.
- ABS‑CBN responded by filing an Answer with compulsory counterclaims, which later involved:
- An amended answer filing liquidated damages claims.
- Subsequent pleadings including a Reply and an Answer ad cautelam by Revillame.
- ABS‑CBN also filed a Verified Application/Motion for TRO or Preliminary Injunction on October 4, 2010 to prevent Revillame from working with a rival network (TV5) on “Willing Willie,” arguing Revillame’s existing contractual ties.
- Disputed Examination of the AIPC Bond
- Revillame posted a bond (AIPC Bond No. G(16)-09314/NSMKT2) accompanied by a Joint Declaration on October 27, 2010 to comply with court requirements.
- ABS‑CBN later raised concerns regarding the authenticity of Revillame’s signatures upon noticing alleged discrepancies in the bond’s signatures.
- ABS‑CBN moved for the examination of these signatures:
- The RTC-Quezon City, Branch 217 granted this motion subject to certain conditions involving representatives from ABS‑CBN, Revillame, and the Branch Clerk.
- Revillame opposed the motion on the ground of irrelevance and questioned the competency of ABS‑CBN’s representatives.
- The RTC modified its order on May 19, 2011, and further amended it on August 22, 2011, clarifying that the examination would occur in the presence of both parties’ representatives after the order attained finality.
- Additional Proceedings and Forum Shopping Allegations
- ABS‑CBN concurrently filed a Copyright Infringement Complaint in RTC-Makati, Branch 66, which Revillame sought to dismiss on multiple procedural grounds.
- Subsequent motions on injunctions, examinations, and motions for voluntary inhibition were filed by both parties.
- The issue of forum shopping surfaced when:
- ABS‑CBN pursued similar relief through its compulsory counterclaim in Civil Case No. Q‑10‑67770 and the Complaint for Copyright Infringement, causing the court to note deliberate and willful forum shopping.
- Various motions were elevated to the Court of Appeals (CA), which rendered decisions on the merits and on procedural aspects including mootness and the requirement of a motion for reconsideration.
- Development in the Court of Appeals and Final RTC Momentum
- CA decisions (CA-G.R. SP Nos. 122086, 122154, and CA-G.R. CV No. 100369) addressed:
- The dismissal of petitions on grounds of mootness and lack of legal issue regarding the examination of Revillame’s signatures.
- The affirmation of the RTC’s amended orders concerning the bond examination.
- The partial reversal and reinstatement of compulsory counterclaims – a matter later challenged on the basis of deliberate forum shopping.
- The Supreme Court eventually resolved:
- Dismissing ABS‑CBN’s petitions in G.R. Nos. 221781 and 225095.
- Partly granting Revillame’s petition in G.R. No. 236167 by reversing the reinstatement of ABS‑CBN’s compulsory counterclaim due to the finding of deliberate and willful forum shopping.
- Taking judicial notice of prior resolutions that conclusively barred issues now rendered moot by subsequent developments, such as the discharge of the AIPC Bond.
Issues:
- Issues Raised by ABS‑CBN in G.R. No. 221781
- Whether the dismissal of Revillame’s petition for certiorari on the basis of mootness was proper, given that the subject bond remained part of the trial court record in the main case.
- Whether the court’s dismissal was premised simply on a mere manifestation by Revillame rather than an adjudication of the merits.
- Whether ABS‑CBN possessed an inherent right to examine the AIPC Bond and whether such right was improperly denied due to Revillame’s assurances and alleged admissions regarding the bond’s authenticity.
- Issues Raised by ABS‑CBN in G.R. No. 225095
- Whether it was proper for the CA to require a motion for reconsideration before instituting a petition for certiorari.
- Whether the CA erred in sustaining the trial court’s order that unfettered ABS‑CBN’s inherent right to examine the bond by finalizing the amended order, thereby allegedly foreclosing ABS‑CBN’s right.
- Whether Revillame’s self‑serving admission regarding the bond signatures should be sufficient to bar ABS‑CBN’s examination claim.
- Issues Raised by Revillame in G.R. No. 236167
- Whether ABS‑CBN engaged in deliberate and willful forum shopping by simultaneously pursuing relief in separate actions (the compulsory counterclaim and a copyright infringement suit) arising from the same set of facts.
- Whether the application of judicial courtesy should allow ABS‑CBN to continue with its counterclaims despite prior findings against forum shopping.
- Whether the doctrine of res judicata and the conclusiveness of judgment bar the current issues, especially in light of resolutions from prior cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)