G.R. No. 171842 - Dy vs. Mandy Commodities, Inc.

On 9 June 1978, the National Government leased a 21,727-square meter government-owned land in Binondo, Manila, to the Philippine National Bank (PNB) for 25 years, expiring on 31 July 2003, with a provision for renewal upon mutual agreement.
On 17 October 1994, PNB sublet 8,530.16 square meters of the land to respondent Mandy Commodities Co., Inc. (Mandy Commodities), who constructed a two-storey warehouse and leased it to tenants.

On 6 May 2002, DENR Secretary Heherson Alvarez initially approved the renewal of PNB's lease for another 25 years.
On 6 August 2002, Secretary Alvarez revoked the renewal to clarify terms and re-evaluate sub-lessees.
On 29 November 2002, Secretary Alvarez approved the renewal of PNB's lease, including Mandy Commodities as a sub-lessee.
On 27 May 2003, new DENR Secretary Elisea Gozun withdrew the lease contract with PNB, effectively canceling the sub-lease with Mandy Commodities.

On 25 July 2003, the Land Management Bureau (LMB) informed PNB of its intent to repossess the property upon lease expiration.
On 30 July 2003, PNB filed an injunction case (Civil Case No. 03-0368-CFM) before the Pasay RTC, seeking to prevent the LMB from taking over the property, claiming the lease had been renewed.
On 28 August 2003, the Pasay RTC denied PNB's application for a Temporary Restraining Order (TRO) and ordered the LMB to take over the property. PNB appealed to the Court of Appeals (CA-G.R. SP No. 78980).
On 29 August 2003, the LMB took possession of the property.
On 18 September 2003, the Court of Appeals nullified the Pasay RTC's order and granted PNB's TRO, but the LMB had already taken possession, rendering the TRO moot.
On 23 September 2003, the Office of the Solicitor General (OSG) opined that the TRO was moot and allowed provisional permits for occupancy.
On 6 October 2003, PNB demanded the LMB to remove its guards, but the LMB refused, citing the OSG's opinion.

On 10 October 2003, Gloria Dy, armed with a provisional permit from the LMB, entered the property and installed her own guards, demanding tenants to secure authorization from her.
On 15 October 2003, Mandy Commodities filed a complaint for damages and injunction (Civil Case No. 03108128) before the Manila RTC, seeking to regain possession.
On 21 October 2003, Mandy Commodities regained possession of the property.

On 30 October 2003, the Court of Appeals affirmed the Pasay RTC's denial of PNB's TRO but declared the LMB's takeover void, as it exceeded the scope of the injunction case.
PNB appealed to the Supreme Court (G.R. No. 164786).

On 7 November 2003, Gloria Dy regained possession of the property.
On 4 December 2003, Mandy Commodities filed a forcible entry case (Civil Case No. 176953-CV) against Gloria Dy before the Manila MeTC.
On 6 April 2004, the MeTC ruled in favor of Gloria Dy, stating that Mandy Commodities lost its right to possess the property after PNB's lease expired.
On 12 July 2004, the Manila RTC reversed the MeTC's decision, ruling that Mandy Commodities had prior possession and a better right to the property. Gloria Dy appealed to the Court of Appeals (CA-G.R. SP No. 86478).

On 15 May 2005, Gloria Dy filed an unlawful detainer case (Civil Case No. 00000004-CV) against Mandy Commodities while the forcible entry case was pending in the Court of Appeals.
Mandy Commodities moved to dismiss the appeal in CA-G.R. SP No. 86478 on the ground of forum shopping.
On 15 September 2005, the Court of Appeals dismissed Gloria Dy's appeal for forum shopping and lack of merit.

Forum Shopping: Forum shopping occurs when a party files multiple cases involving the same parties, issues, and reliefs in different courts to increase the chances of a favorable judgment. Gloria Dy's filing of an unlawful detainer case while the forcible entry case was pending constituted forum shopping, as both cases involved the same parties and issues regarding possession of the property.
Prior Possession: In forcible entry cases, the key issue is prior physical possession. Mandy Commodities had prior possession of the property, and Gloria Dy's possession was based on a provisional permit that was later declared void. Therefore, Mandy Commodities had a better right to the property.
Dismissal of Both Cases: When forum shopping is established, both cases must be dismissed to prevent conflicting decisions and uphold the orderly administration of justice. The Court of Appeals correctly dismissed both Gloria Dy's appeal and her unlawful detainer case.