Facts:

The case involves Silangan Textile Manufacturing Corporation (STMC), TradeWorld Synergy, Incorporated, and Cellu Industries, Incorporated as petitioners against Hon. Avelino G. Demetria, the Presiding Judge of the Regional Trial Court (RTC) of Lipa City, Branch 85, and Luzon Spinning Mills, Incorporated (LSMI) as respondents. The events leading to the case began when LSMI filed a complaint on August 23, 2000, for the collection of a sum of money against STMC. LSMI alleged that from November 19, 1998, to June 14, 1999, certain individuals, Anita, Jimmy, and Benito Silangan, acting as stockholders and officers of STMC, ordered 111,161.60 kilograms of yarn valued at P9,999,845.00. STMC issued 34 postdated checks totaling this amount as payment for the yarn, which were subsequently dishonored due to insufficient funds. Following the dishonor of the checks, LSMI demanded payment from STMC, which failed to comply, prompting LSMI to file the complaint in the RTC. The RTC found the c...

Facts:

1. Parties Involved:

   • Petitioners: Silangan Textile Manufacturing Corporation (STMC), Tradeworld Synergy, Inc., and Cellu Industries, Inc.
   • Respondents: Hon. Avelino G. Demetria (Presiding Judge, RTC Lipa City, Branch 85) and Luzon Spinning Mills, Inc. (LSMI).

2. Transaction and Dispute:

   • LSMI filed a Complaint for Collection of Sum of Money against STMC before the RTC of Lipa City, Branch 85.
   • LSMI alleged that from November 19, 1998, to June 14, 1999, STMC, through its officers (Anita, Jimmy, and Benito Silangan), ordered 111,161.60 kilograms of yarn valued at P9,999,845.00.
   • STMC issued 34 postdated checks totaling P9,999,845.00 as payment. Nine of these checks, amounting to P2,370,405.00, were dishonored for "Drawn Against Insufficient Funds" (DAIF).

3. Legal Actions:

   • LSMI demanded payment, but STMC failed to comply. LSMI then filed the civil case for collection of sum of money.
   • The RTC issued a writ of preliminary attachment against STMC's properties.
   • STMC filed a Motion to Dismiss, citing forum shopping, as LSMI had previously filed criminal cases for violation of Batas Pambansa Blg. 22 (Bouncing Checks Law) against the Silangans before the MTC of Lipa City.
   • The RTC denied STMC's Motion, ruling that the civil and criminal cases involved different parties and issues.

4. Appeal to the Court of Appeals:

   • STMC elevated the case to the Court of Appeals via a Petition for Certiorari, which was dismissed. The CA held that the civil liability of STMC (a corporation) was separate from the criminal liability of its officers.

5. Supreme Court Petition:

   • STMC filed a Petition before the Supreme Court, raising issues on forum shopping, the applicability of Section 1(b), Rule 111 of the 2000 Revised Rules of Criminal Procedure, and the propriety of the writ of preliminary attachment.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Forum Shopping: Forum shopping exists when there is identity of parties, rights asserted, and relief prayed for, such that a judgment in one case would amount to res judicata in the other. In this case, the civil and criminal cases involved the same checks and sought the same relief, making the filing of the civil case improper.
2. Civil Liability in BP 22 Cases: Under Section 1(b), Rule 111 of the 2000 Revised Rules of Criminal Procedure, the civil action for recovery of the amount of dishonored checks is deemed included in the criminal action for violation of BP 22. This rule prevents double recovery and ensures judicial efficiency.
3. Ancillary Remedies: A writ of preliminary attachment is an ancillary remedy dependent on the main action. Since the main civil case was dismissed, the writ of attachment must also be lifted.

Conclusion:

The Supreme Court dismissed Civil Case No. 00-0420 before the RTC of Lipa City and lifted the writ of preliminary attachment issued by the trial court. The Court emphasized the policy against forum shopping and the proper application of the rules on civil liability in BP 22 cases.