G.R. No. 163597 - Hyatt Industrial Manufacturing Corporation vs. Asia Dynamic Electrix Corporation

On April 4, 2001, petitioner Hyatt Industrial Manufacturing Corporation filed a complaint for recovery of money before the Regional Trial Court (RTC) of Mandaluyong City against respondent Asia Dynamic Electrix Corporation.
The complaint alleged that respondent purchased various electrical conduits and fittings totaling P1,622,467.14, but the checks issued in payment were dishonored due to insufficient funds or a closed account.

Prior to the filing of the civil action, petitioner had already initiated separate criminal complaints for violation of Batas Pambansa Blg. 22 against the officers of respondent corporation.
These criminal cases were docketed as I.S. No. 00-01-00304 and I.S. No. 00-01-00300 before the Metropolitan Trial Court of Pasig City and involved the same checks presented in the civil action.

The civil action was alleged to be included in the criminal actions already filed for violation of B.P. 22.
Section 1(b) of Rule 111 of the Revised Rules of Criminal Procedure was cited as prohibiting a separate filing of the civil action.
Accusations of forum shopping and unjust enrichment were raised.

The trial court, in its order dated December 10, 2001, denied the motion to dismiss, ruling that the cause of action arose from non-payment of a contractual obligation (a civil matter) and not solely from the issuance of dishonored checks.

The respondent questioned the trial court’s order before the Court of Appeals.
In its decision dated October 8, 2003, the appellate court reversed the trial court’s ruling by holding that:

The civil action was impliedly instituted with the filing of the criminal cases, as both the criminal and civil actions involved the same parties and the same set of checks.
Under Section 1(b) of Rule 111, the criminal action for violation of B.P. 22 automatically includes the corresponding civil action, thereby barring a separate civil suit.

A motion for reconsideration filed by the respondent was denied by the Court of Appeals in its resolution dated May 14, 2004.

The alleged absence of identity of interests, causes of action, and reliefs between the civil and criminal cases.
The claim that petitioner did not engage in forum shopping nor violated Section 1(b) of Rule 111 when filing the separate civil action.

The petitioner essentially sought relief to proceed separately with the civil action distinct from the criminal proceedings.

Whether there exists an identity of parties, causes of action, and reliefs between the civil case (Civil Case No. MC 01-1493) and the criminal complaints (I.S. No. 00-01-00304 and I.S. No. 00-01-00300) stemming from the same set of dishonored checks.
Whether the filing of a separate civil action following the initiation of the criminal complaints constitutes forum shopping and an attempt to secure a double recovery for the same debt.
Whether the filing of the separate civil action is precluded by the rule under Section 1(b) of Rule 111 of the Revised Rules of Criminal Procedure, which provides that the criminal action for violation of B.P. 22 automatically includes the corresponding civil action.
The application of the doctrine of litis pendentia where the pendency of the criminal action bars the filing of a separate civil suit on the same subject matter.