A violation of the rule on non-forum shopping, specifically the submission of a false certification or non-compliance with undertakings, does not automatically warrant dismissal; dismissal requires willful and deliberate forum shopping, or must follow a motion and hearing, unless the ground for dismissal (like litis pendentia) is evident motu proprio from the pleadings or evidence, a ground which became moot here upon case consolidation.

The dispute arose from conflicting claims over a 50-square meter parcel of land, originally part of a 600-square meter property owned by Domingo Delos Santos. Domingo allegedly sold the entire 600 sqm to Lolita Chu in 1990. Lolita entrusted the deed to Rowena De Leon before leaving for Japan. Subsequently, a different Deed of Sale emerged dated March 1993, purportedly showing Domingo sold 50 sqm to Rowena and the remaining 550 sqm to Lolita. Rowena registered the 50 sqm portion in her name, leading Lolita and Domingo to claim forgery and file for annulment, while Rowena sought the surrender of the title she claimed Lolita wrongfully withheld.

• Respondent Domingo Delos Santos originally owned a 600-square meter parcel of land.
• On December 17, 1990, Domingo allegedly sold the entire 600 sqm portion to Respondent Lolita Chu via a Deed of Absolute Sale.
• Before leaving for Japan on September 5, 1992, Lolita entrusted this Deed of Sale to Petitioner Rowena De Leon.
• A different Deed of Absolute Sale surfaced, dated March 19, 1993, indicating Domingo sold 50 sqm of the land to Rowena and the remaining 550 sqm to Lolita.
• Rowena claimed she bought the 50 sqm portion from Domingo as evidenced by the March 19, 1993 Deed.
• Rowena used allegedly forged documents (including the March 1993 Deed, a Joint Affidavit, and an Agreement of Subdivision) to subdivide the property and register the 50 sqm portion (Lot No. G-2-A-1-A) under her name, obtaining TCT No. 228526.
• Before leaving for Saudi Arabia in June 1997, Rowena entrusted TCT No. 228526 to Lolita.
• On November 18, 1999, Rowena filed LRC Case No. 1322 against Lolita demanding the surrender of TCT No. 228526, alleging Lolita refused to return it.
• On May 17, 2000, Lolita and Domingo filed Civil Case No. 2257 against Rowena for annulment of the March 19, 1993 Deed of Sale and cancellation of TCT No. 228526, alleging their signatures were forged.
• In her answer to Civil Case No. 2257, Rowena admitted Domingo executed the deed only in favor of Lolita but claimed an internal arrangement existed and she had paid consideration for the 50 sqm portion.
• The RTC consolidated both cases and, after trial, found that Rowena had falsified Lolita's and Domingo's signatures on the relevant documents.

• Respondents were guilty of willful and deliberate forum shopping by filing Civil Case No. 2257 while LRC Case No. 1322 was pending, warranting dismissal of their case.
• The Court of Appeals erred in affirming the RTC decision because respondents failed to include the Register of Deeds, allegedly an indispensable party, in their complaint (Civil Case No. 2257).
• The Court of Appeals erred in affirming the dismissal of LRC Case No. 1322 as the certificate of title (TCT No. 228526) belonged to her.
• The lower courts gravely erred in applying the rules of evidence in favor of the respondents.
• The lower courts gravely erred in not finding that the petitioner (Rowena) was a buyer in good faith.

• The Deed of Sale dated March 19, 1993, purportedly transferring 50 sqm to Rowena, was forged; Domingo had sold the entire 600 sqm property to Lolita via a Deed of Absolute Sale dated December 17, 1990.
• Rowena used falsified documents, including the forged March 1993 Deed of Sale, a Joint Affidavit of Vendor and Vendee, and an Agreement of Subdivision, to obtain TCT No. 228526 in her name.
• They were not guilty of forum shopping, and the consolidation of cases rendered the issue moot. (Implicit from CA/SC discussion).
• The RTC correctly found forgery and annulled Rowena's title, and the CA correctly affirmed this decision. (Implicit).

• Whether the respondents were guilty of willful and deliberate forum shopping requiring the dismissal of Civil Case No. 2257.
• Whether the failure to implead the Register of Deeds in Civil Case No. 2257 was a fatal defect.
• Whether the Court of Appeals erred in affirming the RTC's dismissal of LRC Case No. 1322 and its findings regarding the application of evidence and petitioner's status as a buyer in good faith.

• The Supreme Court denied the petition for lack of merit.
• The Court held that violation of the non-forum shopping rule (Rule 7, Section 5) does not automatically warrant dismissal unless it constitutes willful and deliberate forum shopping; otherwise, dismissal requires a motion and hearing, neither of which occurred here, nor did petitioner show willful intent.
• While litis pendentia (another action pending between the same parties for the same cause) could be a ground for motu proprio dismissal under Rule 9, Section 1 if evident from pleadings/evidence, this potential ground became moot when the petitioner agreed to consolidate the two cases (LRC Case No. 1322 and Civil Case No. 2257).
• The failure to implead the Register of Deeds was not fatal, as the Register of Deeds is merely a nominal party whose participation is not essential for adjudicating the rights between Rowena, Lolita, and Domingo.
• The petitioner's arguments regarding the dismissal of LRC Case No. 1322, application of evidence, and her status as a buyer in good faith were issues decided adversely by the RTC but were not raised by the petitioner in her appeal to the CA; therefore, these issues cannot be raised for the first time before the Supreme Court and the RTC rulings on these points are considered final.

• Forum Shopping (Rule 7, Section 5, Rules of Court): Defined as the act of filing multiple suits involving the same parties for the same cause of action, either simultaneously or successively, seeking a favorable judgment. The Court explained that failure to comply with the certification requirement or submission of a false certificate is generally cause for dismissal only upon motion and hearing, or constitutes indirect contempt, unless the acts clearly constitute willful and deliberate forum shopping, which is ground for summary dismissal with prejudice. In this case, willful and deliberate forum shopping was not proven, and petitioner did not move for dismissal on this ground in the lower court.
• Litis Pendentia (Rule 9, Section 1, Rules of Court): Defined as a ground for dismissal when there is another action pending between the same parties for the same cause. The Court noted that trial courts can dismiss a case motu proprio on this ground if it appears from the pleadings or evidence. However, in this case, the potential ground of litis pendentia was rendered moot by the consolidation of the two cases, which petitioner herself agreed to.
• Raising Issues on Appeal: Defined as the principle that issues, points of law, theories, or arguments not raised in the lower court cannot be raised for the first time on appeal. The Court applied this by refusing to consider petitioner's arguments concerning the dismissal of her LRC case, evidence application, and good faith, as these were decided by the RTC but not included in her appeal assignment of errors before the CA.
• Nominal Party: Defined as a party impleaded in an action not because they stand to be directly benefited or injured by the judgment, but often because of a technical requirement or connection to the subject matter (like a public officer acting in an official capacity). The Court identified the Register of Deeds as a nominal party whose non-joinder was not fatal to the case concerning the ownership rights between the main litigants.

• "Failure to comply with the foregoing requirements [certification against forum shopping] shall not be curable by mere amendment... but shall be cause for the dismissal of the case without prejudice, unless otherwise provided, upon motion and after hearing. The submission of a false certification... shall constitute indirect contempt... If the acts of the party or his counsel clearly constitute willful and deliberate forum shopping, the same shall be ground for summary dismissal with prejudice..." (Quoting Rule 7, Section 5, Rules of Court)
• "However, when it appears from the pleadings or the evidence on record that the court has no jurisdiction over the subject matter, that there is another pending action between the same parties for the same cause, or that the action is barred by a prior judgment or by statute of limitations, the court shall dismiss the claim." (Quoting Rule 9, Section 1, Rules of Court)
• "It is a settled rule that no questions will be entertained on appeal unless it has been raised in the lower court."

• Maxicare PCIB CIGNA Healthcare v. Contreras (2013), Spouses Dycoco v. Court of Appeals (2013), Tan v. Commission on Elections (2006), Del Rosario v. Bonga (2001): Cited collectively to support the established rule that points of law, theories, issues, and arguments not brought to the attention of the lower court cannot be raised for the first time on appeal before a reviewing court.
• Anonymous case (638 Phil. 80, 92 (2010)): Cited to support the statement that a violation of the non-forum shopping rule (other than willful/deliberate) does not authorize dismissal without motion and hearing.
• Anonymous case (342 Phil. 383, 386 (1997)): Cited implicitly to support the finality of RTC rulings on issues not raised on appeal to the CA.

• Rules of Court, Rule 7, Section 5 (Certification against forum shopping): Cited to explain the requirements, consequences of non-compliance (dismissal upon motion/hearing), penalty for false certification (indirect contempt), and ground for summary dismissal (willful and deliberate forum shopping). Applied to determine that dismissal of Civil Case No. 2257 was not warranted on this ground.
• Rules of Court, Rule 9, Section 1 (Defenses and objections not pleaded): Cited to explain the court's authority to dismiss a case motu proprio on grounds like litis pendentia if apparent from pleadings or evidence. Applied to show that while litis pendentia was a potential ground, it became moot upon consolidation of the cases.