Case Digest (G.R. No. 208660)
Facts:
Petitioner Peafrancian Sugar Mill, Inc. (PENSUMIL) is a corporation incorporated under Philippine law, engaged in milling sugar. The respondent, Sugar Regulatory Administration (SRA), was established through Executive Order No. 18 in 1986 and is responsible for promoting the sugar industry. On September 14, 1995, SRA issued Sugar Order No. 2, which imposed a lien of P2.00 per LKG-Bag on all sugar products to fund the Philippine Sugar Research Institute, Inc. (PHILSURIN) from September 11, 1995, to August 31, 2005. This order has been successively extended through two later orders, namely, Sugar Order No. 8 (2004-2005) and Sugar Order No. 11 (2009-2010), extending the lien until August 31, 2015. PENSUMIL subsequently filed a petition for prohibition and injunction in the Regional Trial Court (RTC) of Naga City on May 20, 2011, challenging the validity of the Sugar Orders, claiming they exceeded SRA's authority and diverted public funds to a private entity.
In response, SRA an
... Case Digest (G.R. No. 208660)
Facts:
- Petitioner: PeAafrancia Sugar Mill, Inc. (PENSUMIL), a duly organized corporation engaged in the milling and production of sugar.
- Respondent: Sugar Regulatory Administration (SRA), a government agency created under Executive Order No. 18, series of 1986, charged with promoting the growth of the sugar industry by encouraging private sector participation and improving labor conditions.
Background of the Parties
- On September 14, 1995, the SRA issued Sugar Order No. 2, s. 1995-1996, which imposed a lien of ₱2.00 per LKG-Bag on all forms of sugar—raw, improved raw, washed, blanco directo, plantation white, or refined—to fund the Philippine Sugar Research Institute, Inc. (PHILSURIN).
- The Order required that the lien be paid by Manager’s Checks payable to PHILSURIN and remitted within fifteen (15) days upon receipt of the physical sugar.
- Subsequent issuances extended the effect of the original Order:
- Sugar Order No. 8, s. 2004-2005 extended the imposition of the lien until August 31, 2010.
- Sugar Order No. 11, s. 2009-2010 further extended the lien’s imposition until August 31, 2015.
- These issuances are collectively referred to as the “Assailed Sugar Orders.”
Issuance and Extension of the Sugar Orders
- On May 20, 2011, PENSUMIL initiated a petition for prohibition and injunction (docketed as Special Civil Case 2011-0061 in the Naga City Regional Trial Court) challenging the Assailed Sugar Orders.
- PENSUMIL’s allegations against the SRA included:
- The Orders were issued beyond the powers and authority granted to SRA by EO No. 18, s. 1986.
- The levy imposed under the Orders, being a form of public funds, could not constitutionally be channeled to a private entity like PHILSURIN.
Filing of the Petition and Allegations Raised
- In response, both SRA and PHILSURIN filed motions to dismiss the petition on the ground of forum-shopping.
- SRA argued that a related pending case in the Quezon City RTC (Civil Case Q95-25171) raised the same issue on the validity of the Assailed Sugar Orders.
- PHILSURIN contended that a pending collection case (Civil Case 04-239 before the Makati City RTC) similarly involved the same factual matrix, asserting that a final decision in one case would have a res judicata effect on the other.
Motions to Dismiss and the Forum-Shopping Allegation
- In an Order dated November 14, 2011, the Naga City RTC denied the motions to dismiss, affirming that:
- PENSUMIL did not initiate the Makati case; its role was limited to raising the validity issue as a defense.
- Despite overlapping facts, the nature of the cases differed (a petition for prohibition and injunction versus a collection action).
- The RTC reiterated in a subsequent Order dated February 28, 2012 that PENSUMIL did not commit forum-shopping, noting the absence of party identity between the Naga Case and the Quezon City case.
Regional Trial Court Proceedings
- Aggrieved by the RTC’s findings, SRA elevated the matter to the Court of Appeals.
- In a Decision dated April 19, 2013, the CA nullified and set aside the RTC Orders and dismissed the petition for forum-shopping.
- The CA held that even though PENSUMIL was not a party in the Quezon City case, the pending determinations regarding the validity of the Assailed Sugar Orders in that case would have a res judicata effect on the Naga petition.
- A subsequent resolution dated July 31, 2013 denied PENSUMIL’s motion for reconsideration.
Court of Appeals Decision
- During the pendency of the petition, on November 4, 2013, the SRA issued Sugar Order No. 5, s. 2013-2014.
- This Sugar Order revoked the Assailed Sugar Orders, directing all mill companies to immediately cease collecting the ₱2.00 lien, thereby rendering the controversy moot.
Supervening Developments
Issue:
- Evaluation of multiple pending cases (the Naga Case, the Quezon City Case, and the Makati Case) sharing common issues.
- Determination of whether the existence of parallel proceedings imposed a res judicata bar on the petition.
Whether PENSUMIL engaged in forum-shopping by concurrently or sequentially filing cases on the same subject matter (i.e., the validity of the Assailed Sugar Orders) in different forums.
- Analysis of the impact of Sugar Order No. 5, s. 2013-2014, on the justiciability of the controversy.
- Consideration of whether adjudicating on the forum-shopping issue would afford the parties any substantial relief given the moot state of the dispute.
Whether the resolution of the forum-shopping issue would be of any practical legal effect in light of the supervening issuance revoking the Assailed Sugar Orders.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)