Dmpi Employees Credit Cooperative v. Hon. Alejandro M. Velez

Summary

DMPI-ECCI challenged RTC order allowing civil case to proceed despite pending criminal case and lack of forum shopping certification. Supreme Court denied petition, ruling that forum shopping certification was not required when complaint was filed in March 1994, three days before Administrative Circular 04-94 took effect. Court also held that independent civil actions under Article 33 of Civil Code for fraud may proceed without reservation of right to file separately, applying revised procedural rules retroactively. The decision clarifies procedural requirements and relationship between civil and criminal actions for recovery of civil liability.