G.R. No. 127058 - Quinsay vs. Court of Appeals

Petitioner and private respondent were married on December 18, 1968.
They have eight (8) children.
During their cohabitation, they accumulated conjugal assets amounting to millions of pesos.

In 1994, after the parties had separated in fact, private respondent filed a petition for declaration of nullity of their marriage on the ground of psychological incapacity.
At the pre-trial, the court granted the spouses a six (6)-month cooling off period and provided a thirty (30)-day period to arrive at an agreement for the dissolution of their conjugal regime.
Pursuant to the trial court’s order, the parties entered into an “Agreement for the Dissolution of the Conjugal Partnership and Separation of Property,” which was approved by the trial court on September 30, 1994.

On January 31, 1995, petitioner filed an omnibus motion before the trial court seeking to amend the said agreement for the inclusion of other conjugal properties alleged to have been fraudulently concealed by private respondent.
On May 31, 1995, petitioner subsequently filed a petition with the Court of Appeals (CA) to annul the trial court’s order approving the compromise agreement, again alleging fraudulent concealment and misrepresentation of the asset valuations.

The CA dismissed petitioner’s petition on the ground of forum-shopping, noting that the petition was not an appeal from the trial court’s order but a separate suit filed during the pendency of the motion before the trial court.
Petitioner further filed several motions in the CA, including a Motion to Admit Amended Petition, Motion for Reconsideration, Supplemental Motion for Reconsideration, and a Motion for Leave to File a Second Amended Petition—all of which were denied.
The CA explained that there was no evidence of extrinsic fraud, particularly regarding the claim that private respondent had concealed the true value of the family business (Success Unlimited Enterprise).

Whether the petitioner’s filing of parallel motions before the trial court and a petition before the Court of Appeals constitutes forum-shopping and/or litis pendentia.

Determination on whether the two separate filings (the motion to amend the agreement and the petition against the trial court’s order) involved the same parties, the same cause of action, and the same relief, thus satisfying the elements of litis pendentia.
Consideration of whether the filing presented an impermissible attempt by the petitioner to obtain adjudication of the same issue in separate fora.

Whether the alleged extrinsic fraud, involving the concealment of the true worth of conjugal assets, particularly the family business, is a matter that should be resolved by the appellate court.

The issue as to whether the appellate court should delve into factual determinations regarding fraud, especially when such determinations are traditionally within the purview of the trial court as a trier of facts.
Evaluation of whether any alleged fraudulent concealment has been properly substantiated by evidence admissible under the rules of procedure.