REVISED SC CIRCULAR NO. 28-91, February 08, 1994

The attention of the Court has been called to ihe filing of
multiple petitions and complaints involving the same issues in the Supreme
Court, the Court of Appeals or other tribunals or agencies, with the result that
said courts, tribunals or agencies have to resolve the same issues.

1. To avoid the foregoing, in every petition filed with the
   Supreme Court or the Court of Appeals, the petitioner, aside from complying with
   pertinent provisions of the Rules of Court and existing circulars, must certify
   under oath to all of the following facts or undertakings: (a) he has not
   theretofore commenced any other action or proceeding involving the same issues
   in the Supreme Court, the Court of Appeals, or any other tribunal or agency; (b)
   to the best of his knowledge, no such action or proceeding is pending in the
   Supreme Court, the Court of Appeals, or different Divisions thereof, or any
   other tribunal or agency; (c) if there is such other action or proceeding
   pending, he must state the status of the same; and (d) if he should thereafter
   learn that a similar action or proceeding has been filed or is pending before
   the Supreme Court, the Court of Appeals, or different Divisions thereof, or any
   other tribunal or agency, he undertakes to promptly inform the aforesaid courts
   and such other tribunal or agency of that fact within five (5) days
   therefrom.

2. Any violation of this revised Circular will entail the
   following sanctions: (a) it shall’ be a cause for the summary dismissal of the
   multiple petitions or complaints; (b) any wilful and deliberate forum shopping
   by any party and his counsel through the filing of multiple petitions or
   complaints to ensure favorable action shall constitute direct contempt of court;
   and (c) the submission of a false certification shall constitute indirect
   contempt of court, without prejudice to the filing of criminal action against
   the guilty party and the institution of disciplinary proceedings against the
   counsel.