Case Digest (G.R. No. 154618)
Facts:
In Agilent Technologies Singapore (Pte.) Ltd. v. Integrated Silicon Technology Philippines Corporation et al., the petitioner, Agilent Technologies Singapore, is a foreign corporation not licensed to do business in the Philippines. The primary respondent, Integrated Silicon Technology Philippines Corporation, is a Philippine domestic corporation wholly foreign-owned and engaged in electronics manufacturing. Individual respondents Teoh Kiang Hong, Teoh Kiang Seng, Anthony Choo, Joanne Kate M. dela Cruz, Jean Kay M. dela Cruz, and Rolando T. Nacilla are current or former board members of Integrated Silicon. On April 2, 1996, Integrated Silicon and Hewlett-Packard Singapore entered into a five-year Value Added Assembly Services Agreement (VAASA) under which Integrated Silicon would manufacture and assemble fiber-optic components using raw materials consigned by HP-Singapore. With Integrated Silicon’s consent, HP-Singapore assigned its rights and obligations under the VAASA to AgileCase Digest (G.R. No. 154618)
Facts:
- Parties
- Petitioner Agilent Technologies Singapore (Pte.) Ltd.: foreign corporation, unlicensed to do business in the Philippines.
- Respondents
- Integrated Silicon Technology Philippines Corporation: domestic corporation, 100% foreign-owned, engaged in electronics manufacturing.
- Individual directors (current and former): Teoh Kiang Hong, Teoh Kiang Seng, Anthony Choo; Joanne Kate M. dela Cruz, Jean Kay M. dela Cruz; Rolando T. Nacilla.
- Contractual Background
- Value Added Assembly Services Agreement (VAASA), April 2, 1996–April 2001, between Integrated Silicon and Hewlett-Packard Singapore (Pte.) Ltd.:
- Integrated Silicon to manufacture and assemble fiber-optic components locally for export.
- HP-Singapore to consign raw materials, transport machinery, and pay purchase price.
- Provision for annual renewal by mutual written consent.
- Assignment of VAASA (September 19, 1999): HP-Singapore, with Integrated’s consent, assigned all rights and obligations to Agilent.
- Procedural History
- Civil Case No. 3110-01-C (May 25, 2001): Integrated Silicon sued Agilent and officers for specific performance and damages, alleging breach of an oral promise to extend the VAASA.
- Civil Case No. 3123-2001-C (July 2, 2001): Agilent sued Integrated Silicon and individual directors for specific performance, recovery of possession, replevin, preliminary mandatory injunction, and damages, alleging breach of the VAASA and seeking return of equipment/materials.
- Trial Court (Branch 92, Calamba, Laguna)
- Denied respondents’ Motion to Dismiss (grounds: lack of capacity, litis pendentia, forum shopping, failure to state a cause).
- Granted Agilent’s application for writ of replevin (Order dated September 4, 2001).
- Court of Appeals (CA-G.R. SP No. 66574)
- Entertained respondents’ petition for certiorari without prior motion for reconsideration.
- Annulled the RTC Order and dismissed Civil Case No. 3123-2001-C (Decision dated August 12, 2002).
- Supreme Court petition: Agilent challenges CA Decision on grounds of procedural and substantive error.
Issues:
- Whether the Court of Appeals erred in entertaining respondents’ petition for certiorari without a prior Motion for Reconsideration of the RTC’s September 4, 2001 Order.
- Whether the Court of Appeals erred in dismissing Civil Case No. 3123-2001-C on the grounds of litis pendentia and forum shopping instead of consolidating the case or upholding the writ of replevin.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)