In the case of Heirs of Juan Valdez vs. Court of Appeals, the Supreme Court addressed a situation where two conflicting resolutions were issued on the same date. The first resolution dismissed the case without prejudice due to a violation of the rule against forum shopping, while the second resolution required the respondent to comment on the petition. The Supreme Court ruled that the mistake of the court should not prejudice the parties, and clarified that the Court of Appeals (CA) had the power to correct its error and proceed with the case, emphasizing that the re-filing of the petition to address the deficiency was permissible and did not constitute forum shopping given the initial dismissal without prejudice. This decision underscores the judiciary’s commitment to rectifying its errors to ensure fair and just outcomes.

Navigating Judicial Lapses: When Conflicting Rulings Collide

The controversy began with Civil Case No. 00-6015 in the Regional Trial Court (RTC) of Antipolo City, where the heirs and spouses Malvar were plaintiffs in an action for quieting of title. The RTC issued an injunction order and a writ of preliminary mandatory injunction in their favor. Lopez Resources, claiming the writ was improperly enforced against its property, filed a petition for certiorari and prohibition with the Court of Appeals (CA), docketed as CA-G.R. SP No. 76286. This first petition led to the issuance of two conflicting resolutions on May 5, 2003. One resolution dismissed the petition without prejudice for a deficiency in the certification against forum shopping, while the other required comments from the respondents and rectification of the deficiency by Lopez Resources. This unusual situation prompted Lopez Resources to re-file the petition as CA-G.R. SP No. 77615. The core legal issue revolved around the effect of these conflicting resolutions and whether the re-filing constituted forum shopping.

The Supreme Court acknowledged the error made by the CA’s Ninth Division in issuing two conflicting resolutions but emphasized that the intent was to allow rectification of the deficiency in Lopez Resources’ non-forum shopping certification. According to Section 5, Rule 7 of the Revised Rules of Court, failure to comply with forum shopping requirements results in dismissal without prejudice. The Court noted that the CA could also require respondents to comment, with the petitioner undertaking rectification. This approach aligns with established jurisprudence where initiatory pleadings with defective verifications and certifications are allowed on the ground of substantial compliance. The Court cited several cases supporting this view, such as Vicar International Construction, Inc. v. FEB Leasing and Finance Corp., where the subsequent submission of required documents was considered substantial compliance, justifying relaxation of procedural requirements in the interest of justice.

The Court determined that the CA’s action was legally above board, despite the mistake in releasing two conflicting resolutions. Absence of partiality or disregard of applicable laws meant no grave abuse of discretion. The mistake was not an exercise of discretion, much less its abuse. The principle that parties should not suffer for the court’s mistake was central. The Court found that Lopez Resources’ re-filing was a legitimate choice, accepting the dismissal and promptly addressing the deficiency before the resolution became final. This indicated that Lopez Resources kept its petition legally alive. The Court stated that the conflicting resolutions meant no definite determination was made by the court, negating any finality until clarification. The clarificatory resolution of August 1, 2003, was thus valid. Faced with the mistake, the CA acknowledged it and acted to rectify it. CA-G.R. No. SP 76286 remained the viable case, like the “mother” case, which gave rise to the re-filed case. The cancellation of the raffle of the re-filed case and incorporation of its contents with the first petition was a valid move under the circumstances, justified by remedial measures addressing the mistake.

Even if the first resolution became final, the rule on immutability of judgment does not apply where modifications involve correction of clerical errors, nunc pro tunc entries causing no prejudice, or void judgments.

“To be sure, the rule does not apply in cases where a supervening event – such as the mistake undisputably committed by the court (i.e., the unintended release of one of the resolutions, thus resulting in the conflict and confusion) – took place.”

In the case of Natalia Realty Inc. v. Court of Appeals, the Supreme Court held that a supervening event can warrant an exception to the rule on immutability. The Court also referenced Rule 31 of the Revised Rules of Court on consolidation, stating that consolidated cases pertain to the Justice with the lowest docket number if they are of the same kind. This analogy underscored the intent to treat the re-filed case as an integral part of the first petition.

The issue of forum shopping was rendered moot, as the initial order dismissed the case without prejudice. Lopez Resources acted within the bounds of the dismissal order, refiling the petition. As the Court explained,

“Insofar as it was concerned, its first petition had been dismissed without prejudice; hence, there was no bar, either by way of forum shopping, litis pendentia or res adjudicata, to the petition it re-filed.”

The Court emphasized Lopez Resources’ good faith, citing its immediate filing of a Manifestation and Motion for Clarification and a Manifestation and Compliance. The Court was disturbed by the carelessness exhibited in handling the resolutions, stating that public officers must bring prudence and caution to their duties. The Court cited Ulat-Marrero v. Torio, Jr., highlighting the importance of maintaining the judiciary’s good name and standing as a true temple of justice.

This approach contrasts with situations where parties deliberately seek favorable outcomes by filing multiple suits, a practice the courts strongly discourage. In this instance, the actions of Lopez Resources were deemed justifiable due to the circumstances created by the court’s error, preventing any finding of bad faith or intent to manipulate the judicial process.

FAQs

What was the key issue in this case?	The primary issue was whether the conflicting resolutions issued by the Court of Appeals prejudiced the case and whether Lopez Resources committed forum shopping by re-filing its petition.
What did the first resolution state?	The first resolution dismissed the petition without prejudice due to a deficiency in the certification against forum shopping.
What did the second resolution state?	The second resolution required comments from the respondents and rectification of the deficiency in the non-forum shopping certification by Lopez Resources.
Why did Lopez Resources re-file the petition?	Lopez Resources re-filed the petition to correct the deficiency in the non-forum shopping certification, as allowed by the dismissal without prejudice.
Did the Supreme Court find Lopez Resources guilty of forum shopping?	No, the Supreme Court found that Lopez Resources did not commit forum shopping because the initial dismissal was without prejudice, allowing for the re-filing of the petition.
What was the significance of the August 1, 2003 Resolution?	The August 1, 2003 Resolution clarified the conflicting May 5, 2003 resolutions, affirming that CA-G.R. SP No. 76286 remained the viable case.
What rule applies to deficiencies in forum shopping certifications?	Section 5, Rule 7 of the Revised Rules of Court states that failure to comply with forum shopping requirements results in dismissal without prejudice.
What did the Court say about the conflicting resolutions?	The Court said that while the conflicting resolutions were a mistake, the intent was to allow rectification of the deficiency and that parties should not suffer from the court’s error.

This case highlights the judiciary’s role in correcting its own errors to ensure fairness. It serves as a reminder of the importance of due diligence in court proceedings and the principle that parties should not be penalized for inadvertent mistakes by the court. The ruling underscores that dismissals without prejudice offer an opportunity to rectify deficiencies, and re-filing under such circumstances does not constitute forum shopping.

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: Heirs of Juan Valdez, SPS. Potenciano Malvar and Lourdes Malvar vs. The Honorable Court of Appeals and L.C. Lopez Resources, Inc., G.R. No. 163208, August 13, 2008