Case Summary (G.R. No. 174356)
Applicable Law
– 1987 Philippine Constitution (decision date post-1990)
– Rule 59, Section 1(b), Rules of Civil Procedure (receivership)
– Republic Act No. 8048 (agrarian dispossession)
Factual and Procedural Background
- Vargas owned the property but, due to professional commitments, contracted Evelina to cultivate and manage it in trust, sharing gross sales equally.
- Vargas filed a civil complaint in RTC Branch 65 of Bulan, Sorsogon, for recovery of possession, rent, damages, and a prayer for receivership, alleging Evelina’s failure to remit her share.
- Evelina and Aida pleaded that the RTC lacked jurisdiction, as the dispute was agrarian in nature.
- The RTC dismissed for lack of jurisdiction, deeming the parties to be agrarian tenants under DARAB’s exclusive competence.
- Vargas appealed to the Court of Appeals and moved for receivership. On April 12, 2006, the CA placed the property under receivership to preserve its fruits.
- Parallel to the CA appeal, Vargas filed three estafa complaints in RTC Olongapo City and a DARAB dispossession case, each seeking provisional receivership.
Issues Presented
- Whether Vargas’s multiple filings constitute forum shopping.
- Whether the CA erred in appointing a receiver over the disputed land.
Forum Shopping Analysis
– Forum shopping requires (1) identity of parties, (2) identity of rights and reliefs, and (3) such similarity that judgment in one case operates as res judicata in another.
– Although Vargas sought receivership in multiple proceedings, the underlying causes differed:
• Civil suit for recovery of possession and accounting of fruits
• Criminal estafa charges for misappropriation of produce
• Agrarian dispossession under RA 8048 for unauthorized cutting of trees
– Receivership is an ancillary remedy, not an independent cause of action; its grant in one forum does not preclude or decide the merits of another.
– Conclusion: No forum shopping, as each suit asserted distinct rights and sought different reliefs.
Receivership Analysis
– Under Rule 59, Section 1(b), receivership may be granted only when the subject property is in imminent danger of loss, removal, or material injury, necessitating preservation.
– Vargas’s complaint centered on Evelina’s alleged failure to account, not on imminent destruction or waste of the land or its productive capacity.
– Receivership is an e
Case Syllabus (G.R. No. 174356)
Facts and Case
- Respondent Fidela Y. Vargas owned a five-hectare property in Sorsogon, comprising mixed coconut land and rice fields.
- Petitioner Evelina G. Chavez and her daughter, Aida C. Deles, lived on a remote portion of the land, planting coconut seedlings and supervising the harvest of coconuts and palay.
- Fidela and Evelina agreed to divide the gross proceeds from the land’s produce equally; Evelina was to hold in trust and remit Fidela’s share of the profits.
- Fidela alleged that Evelina and Aida failed to account for or pay her half of the profits and refused to turn over administration of the property upon demand.
Procedural History
- Fidela filed a complaint before the Regional Trial Court (RTC) of Bulan, Sorsogon, for recovery of possession, rent, and damages, with a prayer for the immediate appointment of a receiver.
- Evelina and Aida moved to dismiss on the ground that the RTC lacked subject-matter jurisdiction, the dispute being agrarian in nature.
- The RTC dismissed the complaint for lack of jurisdiction, finding Evelina and Aida to be tenants sharing in the gross sales and noting pending agrarian applications by both parties.
- Fidela appealed to the Court of Appeals (CA) and simultaneously moved for the appointment of a receiver.
- On April 12, 2006, t