G.R. No. 171247 - Villamor, Jr. vs. Manalastas

Case Summary (G.R. No. 171247)

Procedural History and Movements

The respondent filed a civil complaint against petitioner (docketed Civil Case No. 70251). The case was raffled to Branch 155, whose judge inhibited; it was then re‑raffled to Branch 268 (Judge Manalastas). Petitioner filed three Motions for Inhibition before the RTC, which Judge Manalastas denied in an Omnibus Order dated October 17, 2005. Petitioner filed a Petition for Certiorari with the CA on November 7, 2005, assailing the denial of inhibition. Prior to and contemporaneous with the CA petition, petitioner also filed (a) a Motion for Reconsideration (MR) with Motion to Lift Default Order in the RTC on November 3, 2005, and (b) an administrative complaint with the Office of the Court Administrator and a Motion for Inhibition on Account of Administrative Case with the RTC in mid‑November 2005.

Grounds for the Motions for Inhibition

The Motions for Inhibition alleged (i) that Judge Manalastas and the respondent had stood as godparents to a child of a common friend, and (ii) that the judge’s husband was a partner in a law firm which, by letter, asserted a claim against petitioner that appeared similar to the respondent’s claim. These factual predicates were advanced to support claims of bias and partiality.

RTC Omnibus Order and CA Petition

Judge Manalastas denied the Motions for Inhibition in the Omnibus Order (Oct. 17, 2005). Petitioner then pursued extraordinary relief in the CA by way of a petition for certiorari (filed Nov. 7, 2005) under Rule 65, seeking annulment of the Omnibus Order insofar as it denied inhibition and an order directing the judge’s inhibition. Meanwhile the MR with Motion to Lift Default Order (filed Nov. 3, 2005) sought reconsideration and setting aside of the entire Omnibus Order; petitioner later filed an administrative complaint and related motions.

CA Resolution Dismissing the Petition for Forum Shopping

The CA dismissed petitioner’s Petition for Certiorari on January 31, 2006, on the ground of forum shopping. The CA concluded that the MR with Motion to Lift Default Order sought reconsideration and setting aside of the Omnibus Order in its entirety; that the Motion for Inhibition on Account of Administrative Case and the administrative complaint introduced the same grounds; and that these remedies, pending in different tribunals, sought one and the same relief—Judge Manalastas’s inhibition—such that petitioner pursued multiple remedies concurrently in different fora.

Issues Presented to the Supreme Court

The Supreme Court framed two issues: (1) whether the petitioner engaged in forum shopping; and (2) whether Judge Manalastas’s refusal to inhibit herself from hearing the civil case was improper.

Legal Standards Applied

The Court applied the 1987 Constitution framework and pertinent provisions of the Rules of Court. It reiterated the doctrine that forum shopping involves instituting two or more suits in different courts successively or simultaneously to obtain relief on the same or related causes, and that relief available in the ordinary course of law precludes premature resort to a petition for certiorari (Rule 65, Sec. 1). The Court invoked the test for litis pendentia—identity of parties, substantial identity of causes of action, and identity of reliefs—along with the policy objectives behind the prohibition of forum shopping and the certification against forum shopping under Section 5, Rule 7. On disqualification/inhibition, the Court distinguished compulsory inhibition (enumerated in first paragraph, Section 1, Rule 137) from voluntary inhibition, which is discretionary and requires clear and convincing evidence of bias to overcome the presumption of judicial impartiality.

Supreme Court’s Conclusion on Forum Shopping

The Court found forum shopping established. It emphasized that the MR with Motion to Lift Default Order prayed to have the Omnibus Order “RECONSIDERED AND SET ASIDE” without qualification, thereby encompassing all rulings in the Omnibus Order, including the denial of the Motions for Inhibition. The Petition for Certiorari sought annulment of the Omnibus Order insofar as it denied inhibition and an order of inhibition; the Motion for Inhibition on Account of Administrative Case likewise sought inhibition. Because three remedies—MR in the RTC, Petition for Certiorari in the CA, and administrative proceedings/Motion for Inhibition on Account of Administrative Case—were concurrently pending and sought substantially the same relief founded on the same facts, the Court held that petitioner willfully pursued multiple remedies in different tribunals and thus engaged in forum shopping. The Court observed petitioner’s failure to expressly limit the MR to a partial reconsideration and noted that allegations underpinning the administrative complaint were materially identical to those in the Motions for Inhibition.

Relation to Rule 65 and Certification Requirements

The Court reiterated that Rule 65 requires absence of an adequate remedy in the ordinary course of law; filing a petition for certiorari while an ordinary remedy (MR) was still pending violated that requirement

Case Syllabus (G.R. No. 171247)

Facts

The underlying controversy arose from a complaint filed by Leonardo S. Umale (respondent) against Alfredo L. Villamor, Jr. (petitioner) and others with the Regional Trial Court (RTC) of Pasig City, docketed as Civil Case No. 70251 and filed on January 13, 2005.
The complaint sought to compel the petitioner to account for, pay, and deliver rental payments allegedly in the petitioner's possession.
The case was originally raffled to Branch 155 (Judge Luis R. Tongco), who voluntarily inhibited himself upon respondent's motion; the case was thereafter re-raffled to Branch 268 (Judge Amelia C. Manalastas).
During the pendency of the RTC proceedings, petitioner filed multiple motions to disqualify Judge Manalastas: Motion for Inhibition, Supplemental Motion for Inhibition, and Second Supplemental Motion for Inhibition, contesting Judge Manalastas’s impartiality.
The petitioner alleged two principal bases for disqualification: (1) that Judge Manalastas and the respondent stood as godparents to a child of a common friend; and (2) that the Law Firm of Ponce Enrile Reyes and Manalastas (with Jesus M. Manalastas as signatory and husband of the judge) wrote to petitioner regarding a purported claim similar to that asserted by respondent.

Procedural History (RTC → CA → Supreme Court)

Judge Manalastas issued an Omnibus Order dated October 17, 2005, denying among others the Motions for Inhibition.
Petitioner filed a Petition for Certiorari with the Court of Appeals (CA) on November 7, 2005, under Rule 65, challenging the Omnibus Order insofar as it denied his Motions for Inhibition.
Prior to the CA’s November 16, 2005 resolution requiring respondent to comment, the parties had filed various manifestations, motions, and filings in both the RTC and the CA, including a Motion for Reconsideration with Motion to Lift Order of Default (MR with Motion to Lift Default Order) filed in the RTC on November 3, 2005.
Petitioner filed an Administrative Complaint for Gross Ignorance of the Law or Procedure and for Bias and Partiality with the Office of the Court Administrator on November 11, 2005, and subsequently filed a Motion for Inhibition on Account of Administrative Case in the RTC on November 12, 2005.
The CA dismissed the Petition for Certiorari by resolution dated January 31, 2006 (CA-G.R. SP No. 91940) on the ground of forum shopping.
Petitioner sought review by the Supreme Court (Rule 45 petition), which resolved the matter in a decision by Justice Brion dated July 22, 2015 (764 Phil. 456), denying the petition and affirming the CA resolution.

Motions for Inhibition and Grounds Asserted

Petitioner’s Motions for Inhibition (March 1, 2005; April 12, 2005; June 21, 2005) asserted bias and grounds to disqualify Judge Manalastas, specifically:
- The social connection (stood as godparents with respondent to a child of a common friend).
- Alleged connection via the judge’s husband’s law firm (Ponce Enrile Reyes and Manalastas) having written to petitioner on a claim similar to respondent’s.
Petitioner later pursued:
- MR with Motion to Lift Default Order in the RTC (filed November 3, 2005), which prayed that the Omnibus Order dated October 17, 2005 be “RECONSIDERED AND SET ASIDE” and requested that petitioner’s motions to dismiss be granted and the order of default be lifted or set aside.
- Petition for Certiorari with the CA (filed November 7, 2005) specifically seeking annulment of the Omnibus Order insofar as it denied the Motions for Inhibition and an order inhibiting Judge Manalastas.
- Administrative Complaint to the Office of the Court Administrator (filed November 11, 2005) and a Motion for Inhibition on Account of Administrative Case in the RTC (filed November 12, 2005), grounded on allegations of gross ignorance of the law and bias and partiality (which included the refusal to inhibit).

RTC Omnibus Order (October 17, 2005)

Judge Manalastas issued an Omnibus Order denying the Motions for Inhibition.
The Omnibus Order was characterized by the judge as finding the petitioner’s allegations insufficient to overcome the presumption that a judge will perform duties impartially and without fear or favor.
The MR with Motion to Lift Default Order sought reconsideration and full setting aside of that Omnibus Order.

Court of Appeals Proceedings and Filings

On November 11 and 18, 2005, respondent filed a Manifestation with Motion to Dismiss Petition and a Supplemental Manifestation/Motion to Dismiss, alleging forum shopping by petitioner because the same issues were pending before the RTC (MR with Motion to Lift Default Order and Motion for Inhibition on Account of Administrative Case).
Petitioner filed multiple manifestations with the CA, disclosing (a) the filing of the administrative complaint and (b) the filing of the Motion for Inhibition on Account of Administrative Case in the RTC.
The CA required respondent to comment on the petition (resolution dated November 16, 2005); respondent filed comment on December 14, 2005.
The CA found the Petition for Certiorari and the pending motions in the RTC prayed for the same relief and constituted forum shopping; respondent’s motion to dismiss was granted.

Court of Appeals Resolution (January 31, 2006)

The CA dismissed the petition for certiorari on the ground of forum shopping.
The CA’s dispositive language: “WHEREFORE, premises considered, the private respondent’s motion and supplemental motion to dismiss the petition are GRANTED. The instant petition is hereby DISMISSED. SO ORDERED.”
The CA noted the MR with Motion to Lift Default Order sought reconsideration of the Omnibus Order in its entirety and that petitioner later filed a Motion for Inhibition on Account of Administrative Case raising substantially the same grounds as those in the Motions for Inhibition and the petition.

Issues Presented to the Supreme Court

Whether the petitioner engaged in forum shopping.
Whether Judge Manalastas’s decision to continue hearing the civil case was improper.

Petitioner’s Contentions (as presented in the petition and reply)

The CA dep