### Facts:
The case emerged from a legal dispute involving the possession and ownership of parcels of land, specifically Lot 3-F, by the Bradford United Church of Christ, Inc. (BUCCI) against members of the Mandaue Bradford Church Council, the Mandaue Bradford Church (MBC), and the United Church of Christ in the Philippines, Inc. (UCCPI). BUCCI initiated a Complaint for unlawful detainer and damages against the respondents in the Municipal Trial Court in Cities (MTCC) of Mandaue City, docketed as Civil Case No. 4936. This action sought to address material possession of Lot 3-F but came under scrutiny for the failure to comply with the certification against forum shopping, given an earlier case (Civil Case No. MAN-1669) filed by UCCPI and MBC against BUCCI for recovery of ownership of the same lot and another, Lot 3-C, before the Regional Trial Court (RTC). The MTCC dismissed BUCCI’s complaint for this non-compliance. On appeal, the RTC upheld this dismissal, leading BUCCI to elevate the matter to the Court of Appeals (CA), which also sided against BUCCI for similar reasons. BUCCI then took the case to the Supreme Court via a Petition for Review on Certiorari.
### Issues:
1. Whether the filing of an unlawful detainer case by BUCCI during the pendency of a recovery of ownership case constituted forum shopping.
2. Whether the principles of litis pendentia or res judicata apply, given the concurrent and successive actions regarding the same parcels of land (Lot 3-F).
### Court’s Decision:
The Supreme Court ruled in favor of BUCCI, finding merit in the petition. It clarified that forum shopping involves the filing of multiple suits involving the same parties and cause of action, either simultaneously or successively, for the purpose of obtaining a favorable judgment. The Court determined there was only an identity of parties between the two cases but not an identity of cause of action. The unlawful detainer case concerned material possession (possession de facto) of Lot 3-F, distinct from the recovery of ownership case which argued for legal ownership. It underscored that a decision in one does not bar the decision or constitute res judicata in another due to the lack of identity in cause of action, subject matter, and relief sought. Consequently, the judgment of the MTCC dismissing the unlawful detainer case was reversed, and the court was directed to proceed with BUCCI’s complaint.
### Doctrine:
The Supreme Court reiterated the principles surrounding forum shopping and the distinct nature between actions for recovery of ownership and unlawful detainer. It highlighted that identity of parties alone does not constitute forum shopping and emphasized the importance of distinguishing between the cause of action and the relief sought in determining the applicability of litis pendentia and res judicata.
### Class Notes:
1. **Forum Shopping**: Filing of similar suits to obtain a favorable judgment; requires identity of parties, cause of action, and relief sought.
2. **Litis Pendentia**: Calls for dismissal due to the pendency of another case with the same parties, rights asserted, and reliefs prayed for.
3. **Res Judicata**: Bars the re-litigation of a case that has been conclusively decided, requiring a final judgment, jurisdiction over the matter and parties, a judgment on the merits, and identity in parties, subject matter, and cause of action between the first and second actions.
4. **Certification Against Forum Shopping (Rule 7, Section 5 of the Rules of Court)**: A mandatory compliance to declare non-commencement or pendency of similar actions or claims in any court, tribunal, or quasi-judicial agency.
### Historical Background:
This decision delves into the complexities surrounding property disputes within religious institutions in the Philippines, specifically addressing procedural nuances in the approach to litigatory strategy such as the certifications required to avoid forum shopping, along with the pivotal distinctions between possession de facto versus ownership disputes. This case clarifies the non-applicability of res judicata in separate actions for possession and ownership, showcasing the judiciary’s stance on ensuring precise adherence to procedural requirements in the context of overlapping legal suits on property disputes.
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