- Petitioner
- AMADEO SAPUL petitioner-appellant
- Respondent
- JUDGE ESTEBAN S. SIVA et al. respondents-appellees
- Citation
- G.R. No. L-14091
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Bautista Angelo, J.
- Decided
- August 25, 1959
Summary
Supreme Court case involving procedural requirements for motion to dismiss based on litis pendentia. Amadeo Sapul challenged denial of his motion to dismiss, claiming another similar action was pending. The Supreme Court affirmed lower courts' dismissal of his certiorari petition, ruling that the requisites for litis pendentia were not met because there was no identity of parties or subject matter between the two cases. The Court also held that orders denying motions to dismiss are interlocutory and cannot be the basis for certiorari petitions. This case establishes important precedent on the three-part test for litis pendentia: identity of parties, identity of rights/relief, and potential for res judicata effect.