Citation
G.R. No. 120958
Court
Supreme Court
Division
First Division
Ponente
Kapunan, J.
Decided
December 16, 1996

Summary

This case involved forum shopping and fraudulent land ownership claims against a golf course development project. Felipe Layos filed two identical injunction cases - first in RTC Biñan against wrong defendant (denied preliminary injunction), then in RTC San Pedro against correct defendant FEGDI after the first failed. The Supreme Court found this constituted prohibited forum shopping - deliberately seeking a sympathetic court after initial failure. The Court also found no valid cause of action due to fatal inconsistencies in the complaint's annexes: the Affidavit of Self-Adjudication stated the properties were unregistered, contradicting the claimed OCT No. 239. Bureau of Lands investigations confirmed Plan Psu-201 was spurious, originally belonging to different property in Manila for different claimant J. Reed. The case established important precedents on forum shopping penalties and considering complaint annexes when determining sufficiency of cause of action. The Supreme Court dismissed the San Pedro case and reinforced that forum shopping constitutes grave abuse of judicial process warranting summary dismissal.

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By the Intellegal Editorial Board · December 16, 1996

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