G.R. No. 200434 - Tiangco vs. ABS-CBN Broadcasting Corp.

On October 24, 2001, Christine Chua filed a complaint for damages before the Regional Trial Court (RTC) of Caloocan City, Branch 126.
Christine Chua, the petitioner, impleaded her brother, Jonathan Chua, as a necessary co-plaintiff—even though he did not assert any claim for relief.
The complaint named respondents Jorge Torres and Antonio Beltran. Torres owned the 9th Avenue Caltex Service Center, while Beltran, as the head of its Sales and Collection Division, acted on behalf of the establishment.

It was alleged that on April 3, 2000, Jonathan Chua issued a personal Rizal Commercial Banking Corporation (RCBC) check (No. 0412802) in the amount of P9,849.20 for the purchase of diesel oil.
The check was dishonored by the drawee bank on the ground that the account was closed.
Antonio Beltran subsequently sent a demand letter to petitioner, notifying her of the dishonor and demanding payment.

Beltran, without first verifying the true issuer of the check, instituted a criminal action against Christine Chua for violation of Batas Pambansa Bilang 22 (B.P. 22).
A criminal information was filed before the Metropolitan Trial Court (MTC) of Caloocan City, Branch 50, which then issued a warrant of arrest against petitioner.
The execution of the warrant led to intrusive police actions, causing alleged "embarrassment" and "social humiliation" as investigators searched various locations connected to petitioner.

Petitioner alleged that Beltran’s negligence amounted to either malicious prosecution or serious defamation, warranting a claim for moral damages.
It was further claimed that Torres, by virtue of his supervisory role, failed in the duty expected of a diligent guardian, thereby compounding the injury to petitioner.
Additional claims included exemplary damages, attorney’s fees, and costs, with the aggregate damages sought amounting to P2,000,000.

The complaint contained a verification and certification against forum-shopping, which petitioner duly executed. However, Jonathan Chua did not sign any verification or certification document.
The RTC, relying on Section 5, Rule 7 of the Rules of Civil Procedure—which mandates that every plaintiff or principal party must execute the certification—dismissed the complaint on the ground that Jonathan Chua’s failure to sign constituted a violation of this rule.
Petitioner’s motion for reconsideration was subsequently denied, prompting the elevation of the case to the Supreme Court by way of a petition for review under Rule 45.

A core issue emerged regarding whether a misjoined co-plaintiff, who does not assert any claim for relief and is not a real party in interest, should be required to execute the certification and verification against forum-shopping.
The controversy further touched upon the judicial treatment of misjoinder, noting that rules like Section 11, Rule 3 of the 1997 Rules of Civil Procedure do not consider misjoinder as a ground for dismissal but rather prescribe procedures to remedy it.

Whether the absence of Jonathan Chua’s signature in the verification and certification against forum-shopping is a valid ground for dismissing the complaint.

Whether Jonathan Chua, despite being impleaded as a co-plaintiff, qualifies as a real party in interest given that he asserts no claim for relief.
Whether his misjoinder justifies imposing the mandatory certification requirement upon him.

How Section 5, Rule 7 (certification against forum-shopping) and Section 7, Rule 4 (verification) of the Rules of Civil Procedure should be applied to parties who are misjoined.
Whether the rules permit the dismissal of a complaint solely on the basis of technical non-compliance by a misjoined party.

Whether the proper judicial response to the misjoinder of a non-essential party is to dismiss the complaint, or instead, to allow for the correction of the error through amendment or dropping the misjoined party.