Facts:

The case involves Ramon Balite, Jose C. Leabres, and Frederick M. De Borja (the Petitioners) as they confront the Court of Appeals (CA) in connection to Felicidad Sandoval Vda. De Carlos and Teofilo Carlos II (the Respondents). The legal disputes began on September 1, 1995, when Juan De Dios Carlos filed a complaint in the Regional Trial Court (RTC) of Muntinlupa, Branch 256, against the Respondents. The complaint sought various resolutions, including a declaration of the nullity of marriage, child status, recovery of property, reconveyance, monetary claims, and damages, along with a preliminary attachment. On September 7, 1995, the RTC granted a writ of preliminary attachment after Juan De Dios Carlos secured a bond from SIDDCOR Insurance Corporation (the Petitioners’ corporation). This writ was served on the Philippine National Bank (PNB) to garnish the Respondents’ account.

Subsequently, the Respondents filed a motion to discharge the writ of attachment, which the RTC denied.

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Facts:

Procedural Background and Parties

• Petitioner Details
• Ramon Balite, president of SIDDCOR Insurance Corporation (now Mega Pacific Insurance Corporation).
• Counsel for SIDDCOR: Atty. Frederick M. de Borja and Atty. Jose C. Leabres.
• Respondents and Other Parties
• Respondents include Felicidad Sandoval Vda. de Carlos and her son, Teofilo Carlos II.
• A third-party plaintiff, Juan De Dios Carlos, initiated the original complaint.
• Nature of the Original Case
• The complaint filed by Juan De Dios Carlos in the RTC of Muntinlupa sought multiple declarations:
• Nullity of marriage.
• Status of the child.
• Recovery of property and reconveyance.
• Payment of sum of money and damages.
• Prayer for the issuance of a writ of preliminary attachment accompanied the complaint.

Key Events and Timeline

• September 1995
• On September 1, 1995, the complaint was filed in the RTC.
• On September 7, 1995, the trial court granted a writ of preliminary attachment upon the posting of a P20,000,000 bond.
• By September 15, 1995, the writ was issued and served on the respondents’ bank (PNB) via garnishment.
• December 1995 – February 1996
• Respondents filed a petition for certiorari with the Court of Appeals (CA) on December 6, 1995 to nullify the RTC’s attachment order and the notice of garnishment.
• On February 27, 1996, the CA rendered judgment in favor of the respondents, holding that the RTC order and writ lacked factual and legal basis.
• April 1996 Developments
• The RTC rendered summary judgment on April 8, 1996 in favor of Carlos, declaring:
• The marriage in question null and void ab initio.
• Various contracts and property titles null and void.
• Orders for the payment of money, together with interest, and directions to cancel and reissue titles.
• Carlos later filed motions to waive the required presentation of further evidence on damages and attorney’s fees, which were granted by the trial court.
• Execution and Garnishment Proceedings
• On April 29, 1996, Carlos filed a Motion for Execution pending appeal.
• The trial court issued an Order for a writ of execution on May 21, 1996 upon posting another P20,000,000 bond.
• The sheriff served notices of delivery/payment to banks holding the respondents’ funds.
• The Interplay of Concurrent Motions and Appeals
• On June 1996, various motions were filed:
• Respondents moved to discharge the writ; Carlos opposed by filing counter-motions.
• A petition for certiorari in the CA by the respondents in CA-G.R. SP No. 39267 resulted in a favorable judgment, later appealed by Carlos in G.R. No. 125717.
• Subsequent applications for immediate execution of the CA’s judgment on the attachment bond ensued, leading to the issuance of further writs and notices, including a controversial Notice of Garnishment against SIDDCOR.
• Accumulation of Forum Shopping and Contempt Allegations
• SIDDCOR (now MPIC) filed a petition for certiorari with the Supreme Court in G.R. No. 136035, seeking to nullify CA resolutions and to enjoin the enforcement of execution orders.
• Meanwhile, motions for immediate enforcement and for recall/lifting of the notice of garnishment were pursued in the CA (in CA-G.R. CV No. 53229).
• The CA, later on, held petitioners and their counsel in contempt for engaging in what it considered forum shopping, imposing fines and disciplinary measures.
• The CA issued resolutions setting aside certain motions while simultaneously ordering enforcement of the attachment bond judgment despite the pending Supreme Court petition.

Actions Leading to the Supreme Court Review

• Petitioners sought to have the CA set aside its orders enforcing the attachment bond and related writs, arguing that the CA had usurped jurisdiction once the Supreme Court had already entertained the petition in G.R. No. 136035.
• The Supreme Court was called upon to:
• Determine whether the simultaneous filing of remedies in separate forums amounted to impermissible forum shopping.
• Decide if such acts warranted a finding of contempt and punishment against the petitioners and their counsel.
• Address the conflict between the CA’s enforcement of its resolution and the temporary restraining order already issued by the Supreme Court.

Issue:

• Whether the petitioners, by concurrently filing motions in the Court of Appeals and in the Supreme Court, engaged in forum shopping.
• Whether such conduct by the petitioners and their counsel constitutes direct contempt of court warranting fines and disciplinary sanctions.
• Whether the CA, by enforcing the writ of execution and notice of garnishment despite the pending petition for certiorari and the temporary restraining order issued by the Supreme Court, overstepped its jurisdiction.
• How the proper judicial hierarchy and the sequence of remedial measures should control the pursuit of relief when parallel proceedings are already underway.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)