Title
Isla LPG Corp. vs. Leyte Development Co., Inc.
Case
G.R. No. 220262
Decision Date
Aug 28, 2019
A dispute arises between Isla LPG Corporation and Leyte Development Company, Inc. over the termination of a Distributorship Agreement, leading to a case of forum shopping and litis pendentia.
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Case Digest (G.R. No. 220262)

Facts:

  • In 2005, Pilipinas Shell Petroleum Corporation (Shell) and Leyte Development Company, Inc. (LDCI) entered into a Distributorship Agreement for Shellane LPG products in Tacloban City and Southern Leyte.
  • The agreement was effective for three years starting February 1, 2005, and was renewed for another three years beginning March 1, 2008.
  • Before the renewed contract expired, LDCI expanded its distributorship by purchasing Dondon Chua's distributorship for P5 million, covering additional areas in Leyte.
  • Shell sold its shares in Shell Gas (LPG) Philippines, Inc. to Isla Petroleum and Gas, which rebranded Shellane LPG products as "Solane."
  • The rebranding caused delays in product availability, adversely affecting LDCI's sales.
  • LDCI reported territorial encroachment by another Solane distributor but was dissatisfied with Isla's response.
  • Isla terminated the month-to-month Distributorship Agreement effective January 12, 2013, and appointed Supreme Star Oil as the new distributor.
  • LDCI, claiming lost business opportunities and damage to its goodwill, filed a Petition for Declaratory Relief with the RTC-Makati, which was dismissed.
  • LDCI then filed a complaint for breach of contract and damages with the same court, which issued a Writ of Preliminary Injunction.
  • Isla's motion for reconsideration and Shell's motion to dismiss were denied.
  • Isla filed a petition for certiorari with the Court of Appeals (CA), which dismissed the petition, affirming the RTC-Makati's orders.
  • Isla then filed a Petition for Review on Certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, affirming the CA's decision that the case before RTC-Makati should not be ...(Unlock)

Ratio:

  • The Supreme Court held that forum shopping, which results in litis pendentia, occurs when a litigant repetitively avails of several judicial remedies based on the same facts and circumstances.
  • The Court found that LDCI engaged in forum shopping by filing complaints in both RTC-Makati and RTC-Tacloban, as both cases involved the same parties, rights asserted...continue reading

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