Cokaliong Shipping Lines v. Amin

G.R. No. 112233 (July 31, 1996)

Cokaliong annulled Makati RTC's order; SC found issues identical, justified case dismissal.

Facts:

The case involves a petition for certiorari filed by Cokaliong Shipping Lines, Inc. (petitioner) against the Hon. Omar U. Amin, Presiding Judge of the Regional Trial Court (RTC) of Makati, Branch 135, and Prudential Guarantee & Assurance, Inc. (respondents). The petitioner initially filed a Complaint for Damages against Carlos A. Go Thong Lines and Eugenio Manubag, Jr. in the RTC of Cebu, which was assigned as Civil Case No. 11660. The complaint stemmed from a collision that occurred on April 3, 1992, between the petitioner's vessel, M/V Filipinas Tandag, and Go Thong Lines' vessel, M/V Our Lady of Lourdes. The petitioner alleged that the collision was due to the negligence of the defendants.

In response, the defendants filed an Answer with Counterclaim, denying negligence and asserting that the collision was caused by the faulty maneuvers of the petitioner's vessel and the negligence of its crew. Subsequently, on February 1, 1993, Prudential Guarantee & Assurance, Inc., as the insurer of Go Thong Lines, filed a separate Complaint against the petitioner in the RTC of Makati, which was docketed as Civil Case No. 93-319. The insurer claimed subrogation rights after paying Go Thong Lines the amount of P2,420,325.59 for damages, alleging that the collision was caused by the negligence of the petitioner's vessel.

On August 3, 1993, the petitioner filed a Motion to Dismiss the Makati case, arguing that it was barred by the principle of litis pendentia due to the pending Cebu case. The RTC of Makati denied the motion, asserting that the causes of action were not identical. The petitioner’s Motion for Reconsideration was also denied, prompting the filing of the petition for certiorari.

Legal Issues:

  1. Whether the principle of litis pendentia applies to bar the second case (Makati Case) due to the pendency of the first case (Cebu Case).
  2. Whether the identity of parties, causes of action, and issues exists between the two cases.

Arguments:

  • Petitioner’s Argument: The petitioner contended that the two cases involved the same parties, the same causes of action, and the same issues, thus satisfying the requirements for litis pendentia. The petitioner argued that since it was a party in both cases, and the insurer was subrogated to the rights of Go Thong Lines, the identity of parties was established. Furthermore, the petitioner asserted that both cases arose from the same incident and involved the same factual basis regarding negligence.

  • Respondent’s Argument: The respondents argued that there was no identity of parties because Prudential Guarantee was not a party in the Cebu case. They claimed that the Makati case was based on a different cause of action, specifically a claim for subrogation under an insurance contract, which was distinct from the negligence claim in the Cebu case.

Court’s Decision and Legal Reasoning:

The Supreme Court granted the petition, ruling that the trial court erred in denying the motion to dismiss based on litis pendentia. The Court outlined the requisites for litis pendentia, which include:

  1. Identity of parties or representation of the same interest.
  2. Identity of rights asserted and relief prayed for, based on the same facts.
  3. The identity must be such that a judgment in the pending case would amount to res judicata in the other.

The Court found that the petitioner was indeed a party in both cases, and the insurer, Prudential Guarantee, was subrogated to the rights of Go Thong Lines, effectively making it a representative party. The Court emphasized that the reversal of roles (plaintiff in one case and defendant in another) does not negate the identity of parties.

Regarding the second requirement, the Court noted that both cases arose from the same incident and involved the same basic issue of negligence. The allegations in both complaints were founded on identical facts, and the resolution of the Cebu case would determine the liability for the collision, thereby affecting the outcome of the Makati case.

The Court also highlighted that the counterclaim filed in the Cebu case further supported the identity of issues, as it sought similar reliefs based on the same facts.

Significant Legal Principles Established:

  1. The principle of litis pendentia can bar a subsequent case if there is identity of parties, causes of action, and issues, even if the parties' roles are reversed.
  2. A counterclaim is treated as a complaint for purposes of determining identity of causes of action.
  3. Subrogation rights allow an insurer to step into the shoes of the insured, establishing identity of parties in related cases.