- Petitioner
- Silangan Textile Manufacturing Corporation
- Respondent
- Hon. Avelino G. Demetria
- Citation
- G.R. No. 166719
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Chico-Nazario, J.
- Decided
- March 12, 2007
Summary
LSMI filed a civil collection case against STMC for unpaid yarn purchases worth nearly P10 million, evidenced by dishonored checks. LSMI had previously filed criminal BP 22 cases against STMC officers. The RTC and CA found no forum shopping, distinguishing between individual criminal liability and corporate civil liability. However, the Supreme Court reversed, applying the Hyatt precedent and SC Circular 57-97. The Court held that civil actions arising from BP 22 violations are deemed instituted in the criminal cases, preventing separate civil suits. Since both actions involved the same checks seeking the same relief (money recovery), forum shopping existed despite different nominal parties. The civil case was dismissed and the preliminary attachment lifted, as ancillary remedies depend on valid main actions. This decision reinforces the policy against forum shopping and clarifies the mandatory inclusion rule for BP 22 civil actions.