G.R. No. 163175 - City of Makati vs. Municipality of Taguig

On March 13, 1992, then President Corazon C. Aquino approved Republic Act No. 7227, which created the Bases Conversion and Development Authority (BCDA).
Section 4(a) of RA No. 7227 mandates that the BCDA may “own, hold and/or administer the military reservations” including specific military camps such as Fort Bonifacio.

On December 8, 1992, then President Fidel V. Ramos issued Executive Order No. 40, placing under the administration of the BCDA portions of Fort Bonifacio as identified in Plans Swo-00-001265 and Swo-00-001266.
The identified portions of Fort Bonifacio were located in the Municipality of Taguig, Metro Manila.

On November 22, 1993, the Municipality of Taguig filed a complaint in the RTC of Pasig City seeking judicial confirmation of its territorial boundaries.
Taguig contested the unconstitutionality and nullity of Presidential Proclamations Nos. 2475 and 518, arguing that these transferred parts of Fort Bonifacio to the City of Makati without proper authority or plebiscite.
Taguig additionally sought injunctive relief to stop the disposal and conversion of these lands by the Department of Environment and other governmental agencies.

On January 20, 1995, President Ramos issued Special Patent No. 3595 conveying specific tracts in Barangay Fort Bonifacio to the BCDA.
On February 7, 1995, President Ramos canceled Special Patent No. 3595 and issued Special Patent No. 3596, granting certain tracts to the Fort Bonifacio Development Corporation (FBDC).
An Original Certificate of Title (OCT) No. SP-001 was subsequently issued to FBDC on February 10, 1995, covering the tracts conveyed by Special Patent No. 3596.

On April 18, 1996, the City of Makati, along with its mayor, vice mayor, city council members, a congressional representative, barangay captains, and a concerned citizen, filed a petition for prohibition and mandamus before the RTC of Makati.
The petition sought to enjoin the Municipality of Taguig and various respondent officials/entities from exercising jurisdiction, imposing taxes, or processing transactions against the disputed lands.

On May 23, 1996, the Municipality of Taguig moved to dismiss the Makati petition on grounds including lack of jurisdiction, existence of another pending case, violation of forum shopping rules, and improper venue.
Similarly, FBDC and BCDA filed motions to dismiss citing no cause of action, lack of jurisdiction, and impropriety of the petition as a remedy to annul Special Patent No. 3596 and OCT No. SP-001.

On September 25, 1998, the RTC of Makati (Branch 141) issued an Order dismissing Civil Case No. 96-554.

The dismissal was based on the grounds of litis pendentia and violation of the anti-forum shopping rules.
It was determined that there was another pending case (Civil Case No. 63896 in Pasig RTC) involving the same parties and subject matter.

On June 6, 2003, the Court of Appeals affirmed the RTC’s dismissal, reiterating that the Makati petition violated the doctrines of litis pendentia and forum shopping.

Petitions filed by the City of Makati, Jejomar Binay, Ernesto S. Mercado, and other petitioners sought review of the Court of Appeals’ decision.
The petition raised issues regarding alleged violations of the forum shopping rule and the existence of litis pendentia, as well as claims of grave abuse of discretion regarding the issuance of Special Patent No. 3596 and OCT No. SP-001.

Whether or not the petitioners violated the rules on forum shopping in filing multiple actions.

The argument revolves around whether the existence of two actions—Civil Case No. 96-554 (Makati’s petition) and Civil Case No. 63896 (Taguig’s case)—constitutes forum shopping.

Whether or not there is litis pendentia between the Makati RTC petition and the Taguig RTC case.

The crux is if the substantive and factual identities in both cases render the petition for prohibition duplicative and hence dismissible.

Whether the Court of Appeals committed grave error by deciding the appeal solely on the grounds of litis pendentia and forum shopping.

Petitioners argue that issues pertaining to the alleged abuse of discretion in the issuance of Special Patent No. 3596 should also have been entertained.
The contention is that the two cases do not fully overlap in parties, rights, or reliefs, and thus the dismissal was premature or overly broad.