G.R. No. 250800 - Suyen Corporation vs. Danjaq LLC

Private respondent Arsenia Coronel mortgaged a parcel of land in Angeles City (covered by T.C.T. No. 43872) to the Rural Bank of Mabalacat, Inc. to secure a loan of P60,000.00.
Owing to her failure to pay the loan, the bank initiated an extra-judicial foreclosure pursuant to Act No. 3135 (as amended by Act No. 4118), resulting in the sale of the property at public auction.
Petitioners Apolinario Melo, Lilia T. Melo, and Julia Barreto emerged as the highest bidders in the foreclosure sale.

Petitioners filed an ex parte petition for the issuance of a writ of possession with the Regional Trial Court (RTC), Branch 60, Angeles City, seeking possession of the subject property under Act No. 3135.
To counter this, on June 8, 1995, private respondent filed a complaint for a preliminary injunction before RTC, Branch 57, Angeles City, aiming to prevent the consolidation of her property’s title in the names of the petitioners and to exercise her right of redemption.

Litis pendentia due to the existence of another related case;
Forum shopping, arguing that the complaint was improperly filed in a different branch;
Failure of private respondent to attach a certification of non-forum shopping to her complaint.

On July 3, 1995, private respondent amended her complaint by including the required certification of non-forum shopping.
Despite the amendment, on August 7, 1995, the trial court denied petitioners’ motion to dismiss, accepting the complaint’s allegations and the certification regarding the right of redemption and the preventive relief sought.

The complaint alleged that petitioners were about to consolidate the title of the foreclosed property, thereby jeopardizing private respondent’s right to redeem the land within the one-year period provided under R.A. No. 337.
It sought to secure a permanent injunction to prevent the consolidation of the property title with the condition that the right of redemption be fully exercised.

Petitioners elevated the case through a petition for review on certiorari questioning both the forum shopping issue and the certificate’s compliance with Administrative Circular No. 09-94.
The Court of Appeals, on certiorari, upheld the trial court’s decision, while addressing the separate causes of action involved in the petition for possession and the complaint for injunction.

Whether private respondent committed forum shopping by filing her complaint for an injunction in RTC, Branch 57 while a petition for the issuance of a writ of possession was pending in RTC, Branch 60.
Whether private respondent substantially complied with the mandatory requirement of submitting a certification of non-forum shopping under Administrative Circular No. 09-94 with her initiatory pleading.