Case Summary (G.R. No. 233448)
Procedural History
SMPHI filed a petition appealing the resolutions of the Regional Trial Court (RTC) Branch 48 in Bacolod City, which dismissed SMPHI's complaint based on the ground of forum shopping. The RTC determined that SMPHI had previously brought similar issues before other legal forums, leading to conflicting assessments of the same claims.
Background Facts
On April 8, 2011, SMPHI offered to lease four properties owned by the Province of Negros Occidental. Following this offer, the Province publicly auctioned its properties on June 8, 2011, but the initial bidding was unsuccessful. In the second bidding attempt on July 7, 2011, both SMPHI's and ALI's bids were found to be below the appraised property value, leading the Committee to declare the bidding a failure. Subsequently, a negotiated sale was conducted, resulting in the province entering a Deed of Conditional Sale and Contract of Lease with ALI.
Claims and Allegations
SMPHI later filed a complaint seeking the nullification of the Deed of Conditional Sale and Contract of Lease, alleging that the bidding process was manipulated in favor of ALI, constituting fraud. SMPHI based its argument on Article 1409 of the Civil Code, contending that the Province violated existing procurement laws and auditing regulations throughout the bidding process.
Defenses by Respondents
The respondents, including ALI and members of the Committee, countered by asserting that SMPHI was engaged in forum shopping, as it had already filed related petitions in the Commission on Audit (COA) and other courts. They argued that the essence of SMPHI's complaints was already adjudicated and that the legal issues were overlapping.
RTC's Findings on Forum Shopping
The RTC found merit in the respondents' claims regarding forum shopping, affirming that SMPHI's case before the RTC sought to achieve the same legal ends as its prior complaints. The RTC highlighted the commonality of the factual basis and legal issues across the various cases brought forth by SMPHI.
Supreme Court's Ruling
The Supreme Court upheld the RTC's dismissal of SMPHI's complaint. Key to the Court's decision was the reiteratio
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Case Information
- Court: Supreme Court of the Philippines
- Date: November 18, 2020
- Case Number: G.R. No. 233448
- Parties:
- Petitioner: SM Prime Holdings, Inc. (SMPHI)
- Respondents: Alfredo G. Marañon, Jr. (Governor of Negros Occidental), Committee on Awards and Disposal of Real Properties of Negros Occidental, its Members, and Ayala Land, Inc. (ALI)
Procedural Background
- Nature of Petition: Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Lower Court Decisions:
- Resolutions dated March 3, 2017, and July 26, 2017, by Branch 48, Regional Trial Court, Bacolod City dismissing SMPHI's complaint due to forum shopping.
Antecedents of the Case
- Initial Proposal: On April 8, 2011, SMPHI offered to lease four properties owned by the Province of Negros Occidental.
- Public Auction Announcement: On June 8, 2011, the Province issued an Offer to Sell or Lease its properties, detailing eligibility requirements and bid opening dates.
- Governor's Communication: On June 16, 2011, Gov. Marañon informed SMPHI that the Province would sell or lease all properties, encouraging it to participate in the bidding.
- Bidding Outcomes:
- The first bidding on June 24, 2011, failed due to only one participant (ALI).
- The second bidding on July 7,