G.R. No. 235258 - Fenix International, Inc. vs. Executive Secretary

The petition for review on certiorari challenges the Decision and Resolution of the Court of Appeals (CA) which upheld the dismissal of a petition for indirect contempt filed by Fenix (CEZA) International, Inc. (petitioner).
The dismissal was based on the grounds of res judicata and forum shopping, as determined by the Regional Trial Court of Aparri, Cagayan, Branch 8 (RTC Br. 8).

Executive Order No. 156, issued by then President Gloria Macapagal-Arroyo on December 12, 2002, imposed a ban on the importation of used motor vehicles, with specific exceptions.
The constitutionality of EO 156 was upheld in the case of Hon. Executive Secretary v. Southwing Heavy Industries, Inc., where the Court declared the ban valid outside the fenced-in area of the former Subic Naval Base.
Subsequently, EO 418 was issued on April 4, 2005, imposing additional duties on imported used motor vehicles, prompting the petitioner to file a petition for declaratory relief against the respondents.

The Fenix Case sought to declare EO 418 void, claiming it was an invalid exercise of legislative authority and violated constitutional rights.
The RTC Br. 8 initially declared EO 418 unconstitutional but later limited this ruling to Section 2 of EO 418.
The Court affirmed the RTC's ruling, leading to a Writ of Execution that allowed the petitioner to import used motor vehicles.

Another case, Executive Secretary v. Forerunner Multi Resources, Inc., questioned the validity of EO 156, with the Court ruling that EO 156 was a valid exercise of police power and not repealed by EO 418.
The Automotive Rebuilding Industry of Cagayan Valley engaged with the Bureau of Customs (BOC) regarding the enforcement of EO 156, which led to the disallowance of the petitioner's importations.

The petitioner filed a petition for indirect contempt against the respondents, claiming that the disallowance of importations contradicted the Writ of Execution from the Fenix Case.
The respondents argued that the contempt petition was barred by prior judgments and that the petitioner was guilty of forum shopping.

The RTC Br. 8 dismissed the contempt petition, finding that the issues were already settled in previous cases (Southwing and Forerunner) and that res judicata applied.
The RTC concluded that the contempt petition constituted forum shopping and that the Writ of Execution did not imply the repeal of EO 156.

The CA affirmed the RTC's dismissal, reiterating that the issues regarding the importation of used motor vehicles were already resolved in prior cases.
The CA held that the respondents were merely enforcing EO 156, which had been upheld in previous rulings.

The Supreme Court addressed whether the CA correctly upheld the RTC's dismissal based on res judicata and forum shopping.
The Court found that res judicata did not apply because the cases involved different i...continue reading