Case Digest (G.R. No. 154618)
Facts:
Agilent Technologies Singapore (Pte.) Ltd. v. Integrated Silicon Technology Philippines Corporation, G.R. No. 154618, April 14, 2004, First Division, Ynares‑Santiago, J., writing for the Court. Petitioner Agilent Technologies Singapore (Pte.), Ltd. (Agilent), a foreign corporation not licensed to do business in the Philippines, seeks review of the Court of Appeals Decision of August 12, 2002 in CA‑G.R. SP No. 66574, which set aside the Regional Trial Court (RTC), Calamba, Laguna, Branch 92 Order of September 4, 2001 and dismissed Civil Case No. 3123‑2001‑C.The dispute arose from a five‑year Value Added Assembly Services Agreement (VAASA) dated April 2, 1996 between Integrated Silicon Technology Philippines Corporation (Integrated Silicon) and Hewlett‑Packard Singapore (Pte.) Ltd. HP‑Singapore consigned raw materials, transported machinery, and purchased finished fiber‑optic products manufactured by Integrated Silicon for export. On September 19, 1999 HP‑Singapore assigned its rights and obligations under the VAASA to Agilent with Integrated Silicon’s consent.
On May 25, 2001 Integrated Silicon filed Civil Case No. 3110‑01‑C for Specific Performance and Damages, alleging Agilent breached an oral agreement to extend the VAASA. On July 2, 2001 Agilent filed Civil Case No. 3123‑2001‑C for Specific Performance, Recovery of Possession and Replevin, seeking recovery of equipment, machinery and materials left at Integrated Silicon’s plant and prayed for a writ of replevin or, alternatively, a preliminary mandatory injunction, damages and attorneys’ fees. Respondents moved to dismiss Civil Case No. 3123‑2001‑C for lack of Agilent’s legal capacity, litis pendentia, forum shopping and failure to state a cause of action. The RTC (Branch 92) denied the Motion to Dismiss and granted Agilent’s application for a writ of replevin on September 4, 2001.
Respondents did not file a motion for reconsideration but instead petitioned the Court of Appeals for certiorari. After Judge Pozas inhibited, the case was re‑raffled to Branch 35 (where Civil Case No. 3110‑2001‑C was pending). The Court of Appeals granted certiorari, held the RTC order was void for lack of jurisdiction ...(Subscriber-Only)
Issues:
- Was the Court of Appeals obliged to dismiss respondents’ petition for certiorari for failure to file a motion for reconsideration before seeking certiorari?
- Did litis pendentia exist between Civil Case No. 3110‑2001‑C and Civil Case No. 3123‑2001‑C, such that the trial court lacked jurisdiction and the latter case should be dismissed?
- Did respondents engage in forum shopping by filing Civil Case No. 3110‑2001‑C and Civil Case No. 3123‑2001‑C?
- Did Agilent lack the legal capacity to sue because it was an unlicensed foreign corporation doing business in the Philippines?
- Did Civil Case No. 3123‑2001‑C fail t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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