Facts:

The case involves Fenix (CEZA) International, Inc. (petitioner) against several government officials, including the Hon. Executive Secretary and the Commissioner of Customs, among others (respondents). The events leading to this case began on December 12, 2002, when then-President Gloria Macapagal Arroyo issued Executive Order No. 156, which imposed a ban on the importation of all types of used motor vehicles, with certain exceptions. The constitutionality of this order was challenged in the case of Hon. Executive Secretary v. Southwing Heavy Industries, Inc., where the Supreme Court ruled that the ban was valid outside the fenced-in area of the former Subic Naval Base but void within that area.

Subsequently, on April 4, 2005, President Arroyo issued Executive Order No. 418, which imposed additional duties on the importation of used motor vehicles. This prompted Fenix, a domestic corporation engaged in the conversion and maintenance of imported used vehicles, to file a peti...

Facts:

Background of Executive Orders

1. EO 156 (2002): Issued by then President Gloria Macapagal-Arroyo, EO 156 imposed a ban on the importation of used motor vehicles, with exceptions for specific areas like the fenced-in former Subic Naval Base. The constitutionality of Section 3.1 of EO 156 was upheld in Hon. Executive Secretary v. Southwing Heavy Industries, Inc., except for its application to the Subic Naval Base area.

2. EO 418 (2005): Issued by the same President, EO 418 imposed a specific duty of P500,000 on imported used motor vehicles, in addition to regular import duties. This prompted Fenix (CEZA) International, Inc., a company engaged in the conversion and reconditioning of used motor vehicles, to file a petition for declaratory relief before the Regional Trial Court (RTC) of Aparri, Cagayan, Branch 8, seeking to declare EO 418 unconstitutional.

Fenix Case

• The RTC initially declared EO 418 void and unconstitutional in its March 13, 2009 Decision. However, upon reconsideration, the RTC limited its ruling to the unconstitutionality of Section 2 of EO 418 only. This decision was affirmed by the Supreme Court in a Minute Resolution dated November 15, 2010. A Writ of Execution was issued on June 14, 2011, allowing Fenix to proceed with its importations.

Forerunner Case

• Another case, Executive Secretary v. Forerunner Multi Resources, Inc., questioned the validity of EO 156. The Supreme Court ruled that EO 156 was a valid exercise of police power and clarified that EO 418 did not repeal EO 156. The Court also noted that the ruling in the Fenix Case did not affect the validity of EO 156.

Contempt Case

• Following the enforcement of EO 156 by the Bureau of Customs (BOC), Fenix filed a petition for indirect contempt against the respondents, alleging that the BOC's actions contradicted the Writ of Execution issued in the Fenix Case. The RTC dismissed the petition, citing res judicata and forum shopping. The Court of Appeals (CA) affirmed the RTC's decision.

Issue:

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Ruling:

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Ratio:

1. Res Judicata: The doctrine of res judicata requires identity of parties, subject matter, and causes of action. In this case, while the parties and subject matter (importation of used motor vehicles) were similar, the causes of action were different. The Contempt Case dealt with indirect contempt, while Southwing and Forerunner dealt with the constitutionality of EO 156 and EO 418, respectively. Thus, res judicata does not bar the Contempt Case.

2. Forum Shopping: Forum shopping occurs when a party files multiple cases involving the same issues and facts. Since the Contempt Case raised a distinct issue (indirect contempt) not previously adjudicated, there was no forum shopping.

3. Remand for Further Proceedings: The Court emphasized that the Contempt Case should proceed to determine whether respondents violated the Writ of Execution issued in the Fenix Case.

Conclusion:

The Supreme Court ruled that the CA erred in dismissing the Contempt Case based on res judicata and forum shopping. The case was reinstated and remanded to the RTC for further proceedings.