Facts:
Sps.
Norberto De Guzman and
Felicitas C. De Guzman (petitioners) filed a Petition for Review on Certiorari under
Rule 45 assailing the
Decision dated April 26, 2011 of the Court of Appeals (CA) in CA-G.R. CV No. 90392 and the
Resolution dated November 22, 2011, which denied their motion for reconsideration. The controversy arose from two related proceedings in the RTC of Valenzuela City, Branch 75 and Branch 171. Planters Development Bank (Planters Bank) was the registered owner of a parcel of land covered by
Transfer Certificate of Title (TCT) No. V-71509, which had been subdivided into three lots: (1) Lot 1047-C-2-D-1 (ninety square meters), (2) Lot 1047-C-2-D-2 (one hundred eighty-five square meters), and (3) Lot 1047-C-2-D-3 (nine hundred sixty-three square meters). On November 15, 2004,
Republic of the Philippines and the
Toll Regulatory Board (TRB; collectively respondents) filed a complaint for
expropriation against Planters Bank before the RTC of Valenzuela City, Branch 75, docketed as Civil Case No. 264-V-04, to enable the construction and/or rehabilitation of
toll facilities along the
North Luzon Expressway (NLEX) as part of the NLEX Project, specifically concerning Lot 1047-C-2-D-1. On November 22, 2005, Planters Bank sold the entire property covered by TCT No. V-71509 to petitioners. Petitioners then filed a
Complaint in Intervention in the expropriation case, asserting that they were the new owners by virtue of the
Deed of Absolute Sale and demanding payment of
just compensation. In the intervention, petitioners also alleged that respondents had converted another portion of the property consisting of one hundred eighty-five square meters (Lot 1047-C-2-D-2) for road widening and sought payment of just compensation for that taking. The RTC granted the intervention. Petitioners thereafter, through a letter dated August 30, 2006, informed the TRB that they were the new owners and demanded payment of
P1,572,500.00 as just compensation for Lot 1047-C-2-D-2, together with payment for Lot 1047-C-2-D-1, but the TRB refused and failed to pay. Consequently, on September 12, 2006, petitioners filed a separate
Complaint for recovery of possession and/or payment of just compensation before the RTC of Valenzuela City, Branch 171, docketed as Civil Case No. 180-V-06, alleging that they should be paid just compensation for Lot 1047-C-2-D-2, which respondents had included for widening of an existing roadway, and praying for reconveyance if respondents refused to pay. Respondents moved to dismiss, among others, on the ground of violation of the rule against
forum shopping, arguing that petitioners had already intervened in the pending expropriation case involving the same property. The RTC dismissed Civil Case No. 180-V-06 on April 9, 2006 (and later denied petitioners’ motion for reconsideration), ruling that petitioners’ intervention in Civil Case No. 264-V-04 showed forum shopping because both actions involved the same parties and an identity of rights asserted and reliefs prayed for, and because petitioners would present the same evidence to prove ownership and entitlement to just compensation. On appeal, the CA affirmed, holding that there was identity of parties and identity of rights asserted between the expropriation case and the recovery-of-possession case, and that because both lots were covered by a single title, a favorable ruling in the recovery-of-possession case could preempt the intervention resolution in the expropriation case. The Supreme Court, however, granted the petition, reversed and set aside the CA rulings, and ordered the consolidation of Civil Case No. 180-V-06 and Civil Case No. 264-V-04 to expedite resolution.
Issues:
Whether petitioners were guilty of
forum shopping in filing their complaint for recovery of possession and/or payment of just compensation after filing a
Complaint in Intervention in the expropriation case.
Ruling:
Ratio:
Doctrine: