Case Summary (G.R. No. 127058)
Factual Background
In 1994, after their separation, Cesar M. Quinsay filed for a declaration of nullity of their marriage based on the ground of psychological incapacity. The trial court subsequently allowed a six-month cooling-off period for reconciliation and required the parties to negotiate the dissolution of their conjugal partnership. The parties reached an "Agreement for the Dissolution of the Conjugal Partnership and Separation of Property," which was approved by the trial court on September 30, 1994.
Petition for Annulment
On January 31, 1995, Cristina Quinsay filed an omnibus motion to amend the earlier agreement due to alleged fraudulent concealment of additional conjugal properties by her husband. Subsequently, she sought annulment of the trial court's order approving the agreement, which she claimed was based on misrepresentation of the value of the property. This petition was filed with the Court of Appeals but was dismissed for reasons related to forum-shopping.
Court of Appeals Ruling
The Court of Appeals rejected Quinsay's petition citing that her actions constituted forum-shopping; she had filed motions before the trial court concerning the same subject matter while simultaneously pursuing a petition in the appellate court. The appellate court highlighted that both the motion before the trial court and the petition before the CA aimed at the same relief—regarding the amendment of the compromise agreement based on alleged fraudulent actions.
Concept of Forum-Shopping
The court elaborated on the implications of forum-shopping, clarifying that it is not merely about parallel cases but includes the situation where the same parties seek the same relief in different courts. The CA underscored that both the trial court and CA proceedings were addressing the same issue, thus, the existence of litis pendentia, which refers to the presence of multiple cases involving the same issue before the courts.
Grounds for Dismissal
To invoke the principle of litis pendentia, three elements must be present: identity of parties, identity of rights asserted, and identity in the underlying facts. Here, all three elements were evident: the parties involved were the same, the relief sought was identical, and the cases were predicated on the same factual circumstances concerning the properties in question.
Factual Issues and Extrinsic Fraud
The Supreme Court noted that allegations of extrinsic fraud, specifically regarding the supposed deception in signing the compromise
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Case Overview
- The case revolves around a marital dispute between Cristina C. Quinsay (Petitioner) and Cesar M. Quinsay (Private Respondent), who were married on December 18, 1968, and have eight children.
- The couple had accumulated significant conjugal assets during their marriage, valued at millions of pesos.
- The factual separation of the parties occurred in 1994, which prompted Cesar M. Quinsay to file for the declaration of nullity of their marriage based on psychological incapacity.
Procedural History
- At the pre-trial stage, the trial court mandated a six-month cooling-off period, allowing the parties to negotiate a dissolution of their conjugal partnership.
- The parties reached an "Agreement for the Dissolution of the Conjugal Partnership and Separation of Property," which was approved by the trial court on September 30, 1994.
- Subsequently, on January 31, 1995, Cristina filed an omnibus motion to amend the agreement, claiming fraudulent concealment of additional conjugal properties by Cesar.
- On May 31, 1995, Cristina filed a petition with the Court of Appeals (CA) seeking annulment of the trial court's approval of the agreement based on allege