Umale v.

Canoga Park Development Corporation (2011)

FACTS: George Umale and Canoga Park entered into a 2-year lease contract whereby
Umale will lease an 860sqm lot in Ortigas from Canoga. Before the expiration of the
contract, Canoga filed an unlawful detainer case against Umale for violating one
stipulation in the lease contract- that no shopping arcades or retail stores, restaurants,
etc. shall be allowed to be established on the property, except with the prior written
consent from Ortigas & Co. Ltd. Partnership. Apparently, Umale undertook to use the lot
as parking space for light vehicles and site for small drivers, and not use the same for
any other purpose without Canoga’s approval. In addition, he constructed thereat
improvements like restaurant buildings, and other establishments, and subleased the
lot. When the case was already at the CA, the lease contract finally expired, and
another case for unlawful detainer was filed by Canoga against Umale. The RTC ruled
in favor of Umale and dismissed the latter case on the ground of litis pendentia.

ISSUE: WON THERE WAS LITIS PENDENTIA.

RULING: NONE. The court explained that there is litis pendentia if there are two actions
pending between the same parties, two actions are for the same cause of action, there
is identity in the reliefs sought. The two cases involve different causes of action.
The SC mentioned the tests to determine WON two actions are the same:
 whether the same evidence would support and sustain both the first and second
causes of action “same evidence” test
 whether the defenses in one case may be used to substantiate the complaint in
the other
 whether the cause of action in the second case existed at the time of the filing of
the first complaint
The third test would point that there is no litis pendentia. The cause of action in the
second case does not exist when the first case was filed. There will also be no conflict
in the decisions in the two cases. Hence, the two cases are independent with each
other.