G.R. No. 186730 - Yap vs. Chua

On January 9, 2004, Jesse Yap (petitioner) filed a complaint before the Regional Trial Court (RTC) of Makati City (Civil Case No. 04-030) against respondents Eliza Chua and Evelyn Te.
Yap sought the cancellation or discharge of several checks drawn from his account with the Bank of the Philippine Islands (BPI), which were delivered as payment for real properties purchased through Te, a real estate broker.
Yap alleged that the checks were either payable to Te, the property owners, or various financiers, including Chua, who requested that Yap issue checks directly to her instead.
The checks were postdated July 30, 1997, and the total amounts ranged from P960,000 to P10,900,000 per check. Yap stopped payment and closed his account after Te failed to deliver the titles.
Yap also stopped payment on other checks endorsed by Te to Chua without his consent, including two checks payable to Badoria Bagatao.
Yap contended that there was no valid consideration for the contracts and thus sought annulment of the checks.

Chua claimed she released approximately P18,830,000 twice through an intermediary for which Yap issued postdated checks totaling P20,000,000 along with several interest-bearing checks.
Yap allegedly requested multiple extensions and replacements of checks, issuing new ones to cover the principal and interest obligations.
Chua also confirmed endorsement of other checks for rediscounting, which Yap stopped or had dishonored due to account closure.
When Yap did not honor the checks, Chua filed a complaint for sum of money before the RTC of General Santos City (Civil Case No. 6236).

RTC of General Santos City ruled in favor of Chua, ordering Yap and his wife to pay the principal amount of P32,558,332 with interest, moral and exemplary damages, attorney's fees, and costs.
Yap was found liable based on the checks issued.

Chua moved to dismiss Civil Case No. 04-030 on grounds of litis pendentia and forum shopping for failure to inform the court about the pendency of the General Santos case and its appeal.
The RTC of Makati initially denied the motion to dismiss, reasoning that:

The reliefs in the two cases differ (annulment vs. payment).
The rule against forum shopping requires plaintiff to declare prior suits; Yap, as defendant in the General Santos case, was not required to declare pending suits initiated against him.

Chua elevated the case to the Court of Appeals (CA), alleging grave abuse of discretion by the RTC of Makati in refusing dismissal.
The CA granted the petition, set aside the RTC orders, and dismissed Civil Case No. 04-030 due to litis pendentia and violation of the rule against forum shopping, holding that:

There was identity of parties.
There was identity of rights asserted and reliefs prayed for, both founded on the same facts.
The cause of action in Yap's case was effectively the same as his defense in the General Santos case.
Concurrent litigation risked conflicting decisions and constituted abuse of judicial processes.

Yap filed a petition for review, arguing that the causes of action in the two cases were not the same, and thus no forum shopping occurred.
He asserted that his case sought cancellation of checks based on lack of consideration while Chua's sought payment based on the validity of said checks.

Whether the dismissal of Civil Case No. 04-030 on grounds of litis pendentia is justified.
Whether petitioner Jesse Yap committed forum shopping by filing a complaint for annulment of checks after a judgment was rendered against him involving the same subject matter.
Whether the reliefs sought and causes of action in the two cases are substantially identical or materially different.