Case Summary (G.R. No. 123686)
Background Facts
The case concerns a mortgage transaction in which the private respondent, Arsenia Coronel, secured a loan of P60,000.00 from the Rural Bank of Mabalacat, Inc. using a parcel of land in Angeles City (T.C.T. No. 43872) as collateral. Following her default on the loan, the bank initiated extra-judicial foreclosure proceedings under Act No. 3135, resulting in the sale of the property to the petitioners, Apolinario Melo and Lilia T. Melo. The petitioners subsequently sought a Writ of Possession from the Regional Trial Court, Branch 60. In response, Coronel filed an injunction suit against the petitioners before the Regional Trial Court, Branch 57, asserting her right of redemption.
Procedural History
The petitioners filed a motion to dismiss Coronel's injunction complaint on the grounds of litis pendentia, forum shopping, and failure to attach a certification of non-forum shopping. Coronel later amended her complaint to include a certification stating that she had not filed any other similar actions. The Regional Trial Court denied the petitioners' motion to dismiss on the basis that there was sufficient cause of action for Coronel's right to redeem the property.
Legal Issues
The primary issues raised in this petition for review on certiorari were: (1) whether Coronel's actions constituted forum shopping by filing a complaint for preliminary injunction while there was a pending Petition for the Writ of Possession, and (2) whether she substantially complied with the requirements for filing a certification of non-forum shopping.
Forum Shopping Analysis
The Court of Appeals upheld the trial court's decision, clarifying that forum shopping occurs when a party files multiple actions to achieve a favorable judgment through different fora. It distinguished between the petition for a Writ of Possession, which sought physical possession of the property, and the injunction complaint, which aimed to protect Coronel's right of redemption. Thus, since the actions involved different causes and objectives, they did not constitute forum shopping.
Certification of Non-Forum Shopping
However, the petitioners argued successfully that Coronel had failed to meet the mandatory obligations outlined in Administrative Circular No. 09-94 concerning the certification of non-forum shopping. This circular requires that a party certifies, under oath, that no other action involving the same issue has been filed or is pending in any court or tribunal. The absence of such a certification, according to the Court, warranted the dismissal of Coronel’s complaint irrespective of her intentions regarding forum shopping.
Supreme Court Ruling
The Supreme Court concluded that the requirements for filing the certificati
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Case Background
- The case revolves around a petition for review on certiorari regarding a resolution by the Court of Appeals dated January 2, 1996.
- The resolution affirmed the Regional Trial Court, Branch 57, Angeles City's denial of a motion to dismiss filed by petitioners Apolinario Melo, Lilia T. Melo, and Julia Barreto.
- The private respondent, Arsenia Coronel, mortgaged a parcel of land (T.C.T. No. 43872) to secure a loan of P60,000.00 from the Rural Bank of Mabalacat, Inc.
- Due to her failure to repay the loan, the bank executed an extrajudicial foreclosure, selling the property to the petitioners as the highest bidders.
Procedural History
- After acquiring the property, petitioners filed a Petition for Ex-Parte Issuance of a Writ of Possession with the Regional Trial Court, Branch 60, Angeles City.
- In response, Coronel filed a complaint for injunction against the petitioners in the Regional Trial Court, Branch 57, on June 8, 1995.
- Petitioners moved to dismiss Coronel's complaint, citing grounds of litis pendentia, forum shopping, and lack of a certification of non-forum shopping.
Amendments and Trial Court Ruling
- On July 3, 1995, Coronel amended her complaint, including the required certification of non-forum shopping.
- The trial court denied the motion to dismiss, stating that the complaint sufficiently presented a cause of action and that Coronel was exercising her right to redeem the property.