This case underscores the crucial principle that litigants in the Philippines cannot simultaneously pursue the same legal remedies in multiple courts. The Supreme Court reiterated that filing a petition in a higher court while a motion for reconsideration is pending in a lower court constitutes forum shopping, a prohibited practice that undermines the orderly administration of justice. This ruling serves as a warning to parties attempting to circumvent adverse judgments by pursuing parallel legal avenues, emphasizing that choosing a forum and subsequently losing the claim thereat results in being bound by the adverse judgement.

Double-Dipping in Justice: Forum Shopping Foiled

The case of Gaudencia Navarro Vda. de Taroma vs. Sps. Felino N. Taroma arose from a land dispute where the petitioners sought to annul the titles of the respondents. After the Municipal Circuit Trial Court (MCTC) dismissed their complaint, the petitioners appealed to the Regional Trial Court (RTC), which affirmed the MCTC’s decision. Undeterred, the petitioners filed a Petition for Review with the Court of Appeals (CA). While their motion for reconsideration was pending in the CA, they simultaneously filed a Petition for Review on Certiorari with the Supreme Court, seeking the reversal of the same CA decision. This simultaneous pursuit of remedies became the focal point of the Supreme Court’s analysis, highlighting the impermissibility of forum shopping.

The Supreme Court emphasized that Philippine procedural rules do not permit litigants to pursue parallel remedies in different courts concurrently. Forum shopping occurs when a party attempts to avail themselves of multiple judicial remedies in various courts, based on the same facts, circumstances, and issues, either pending or already resolved adversely by one court. The Court referenced several precedents establishing the prohibition against forum shopping. It serves to prevent the decesion.

The Court of Appeals initially dismissed the motion for reconsideration filed by the petitioners declaring it abandoned due to the subsequent filing of a petition with the Supreme Court. Subsequently, the petitioners filed a “Brief Motion for Reconsideration”, but this was noted without action. The Supreme Court agreed with the Court of Appeals, stating that filing a petition for review while the motion for reconsideration was pending was a violation of Section 15, Rule VI of the Internal Rules of the Court of Appeals.

The Supreme Court held that the “Brief Motion for Reconsideration” filed by the petitioners was essentially a second motion for reconsideration. As such, it was correctly noted without action by the Court of Appeals. The Court cited Section 2, Rule 52 of the Rules of Court, which expressly prohibits second motions for reconsideration from being entertained. Therefore, the Supreme Court determined that the Court of Appeals was correct to disregard the motion.

Further, the Court highlighted the significance of finality of judgments. By attempting to resurrect the same issue already decided in their previous petition, the petitioners were attempting to circumvent this well-established legal principle. Litigation must end at some point, and once a judgment becomes final, the issues should be considered resolved. Attempting to revive settled matters undermines the effective administration of justice. The Court concluded that it would not allow the petitioners to re-litigate matters already decided in their prior failed attempt.

The Court further delved into the attempt by the petitioners to rely on the alleged mistake committed by the appellate court. They claimed that because of a probable inadvertence on the part of the clerk of court, the CA allegedly rendered its decision based on their original Petition, rather than their amended one. In its defense, the Court pointed out that CA has full discretion whether to admit or deny the Amended Petition filed before it, further construing the fact that the Amended Petition was never acted upon as a denial of the said petition.

This case clearly illustrates the consequences of attempting to manipulate the judicial process. It underscores the importance of adhering to procedural rules and respecting the finality of court decisions. Parties must choose their legal strategies carefully and accept the outcomes, avoiding the temptation to pursue parallel remedies in hopes of a more favorable result. Engaging in forum shopping not only wastes judicial resources but also undermines the integrity of the legal system.

FAQs

What is forum shopping?	Forum shopping occurs when a party files multiple lawsuits based on the same cause of action, seeking a favorable outcome in different courts simultaneously. It is a prohibited practice aimed at undermining the orderly administration of justice.
Why is forum shopping prohibited?	Forum shopping is prohibited because it wastes judicial resources, creates conflicting rulings, and undermines the integrity of the legal system. It allows parties to seek multiple chances for a favorable decision, potentially leading to unjust outcomes.
What is the effect of filing a motion for reconsideration?	A motion for reconsideration asks the court to review its decision for errors of law or fact. It suspends the period for filing an appeal until the motion is resolved.
What happens if you file a petition in a higher court while a motion for reconsideration is pending?	Filing a petition in a higher court while a motion for reconsideration is pending in a lower court is generally considered forum shopping. The lower court may deem the motion for reconsideration abandoned.
What is the finality of judgment?	Finality of judgment means that a court decision is no longer subject to appeal or modification. It becomes binding on the parties and prevents further litigation of the same issues.
What is the effect of finality of judgment?	Once a judgment is final, the parties are bound by the decision, and the matter cannot be relitigated. This ensures that litigation comes to an end, providing certainty and stability in legal matters.
Can you file a second motion for reconsideration?	Generally, second motions for reconsideration are prohibited. Courts typically do not entertain successive motions for reconsideration of the same judgment or final resolution.
What are the potential consequences of forum shopping?	The potential consequences of forum shopping include the dismissal of the case, sanctions for the party and their lawyer, and potential disciplinary actions against the lawyer. It can also result in adverse rulings and damage to one’s reputation.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Gaudencia Navarro Vda. de Taroma, et al. vs. Sps. Felino N. Taroma, et al., G.R. No. 160214, December 16, 2005