SPLITTING A SINGLE CAUSE OF ACTION AND ITS EFFECTS UNDER PHILIPPINE CIVIL PROCEDURE
(Rule 2, Rules of Court; as amended by the 2019 Amendments to the Rules of Civil Procedure)

1. Concept of a Cause of Action

Definition (Rule 2, Section 2, Rules of Court):
A cause of action is the act or omission by which a party (defendant) violates the right of another (plaintiff). The elements are:
1. A right in favor of the plaintiff;
2. An obligation on the part of the defendant to respect or not violate that right; and
3. An act or omission by the defendant in violation of the plaintiff’s right.
Single vs. Multiple Causes of Action:
- A party may have a single cause of action if all the claims stem from one legal wrong or one delict/act/omission.
- A party has multiple causes of action if different rights arising from different delicts or transactions are violated.

2. What is Splitting a Single Cause of Action?

Definition:
Splitting a single cause of action occurs when a single cause of action—arising from a single transaction or occurrence that violates one right—is divided into several suits or claims. In other words, instead of bringing all claims or all reliefs sought for that single cause of action in one complaint, the plaintiff splits or segments them into separate lawsuits.
Policy Against Splitting:
The Rules of Court expressly prohibit splitting a single cause of action. The rationale is to:
- Prevent multiplicity of suits,
- Avoid harassment of the defendant by filing multiple actions, and
- Promote judicial efficiency and consistency (avoid conflicting judgments).

3. Governing Rule (Rule 2, Sections 3 and 4)

Prohibition (Rule 2, Section 3):

“A party may not institute more than one suit for a single cause of action.”
Effect of Splitting (Rule 2, Section 4):

“If two or more suits are instituted on the basis of the same cause of action, the filing of one or a judgment upon the merits in any one is available as a ground for the dismissal of the others.”

This means that once a party files one case on the basis of a single cause of action, filing another suit or multiple suits based on the same cause is a ground for dismissal, either via litis pendentia (if the first suit is still pending) or res judicata (if there is already a final judgment on the merits in the first suit).

4. Why Is Splitting a Single Cause of Action Prohibited?

Multiplicity of Suits:
The law discourages multiple actions that arise from the same set of facts or transaction because it clogs court dockets and creates the possibility of conflicting decisions.
Harassment of Defendant:
Defendants should not be subjected to several lawsuits for essentially the same wrongdoing.
Principle of Res Judicata:
Once a court of competent jurisdiction renders final judgment, it binds the same parties and bars subsequent suits involving the same cause of action.

5. Illustrative Examples

Example of Splitting:
- Suppose a lessee fails to pay monthly rentals for January to June of a given year, and the lessor has a right to collect all unpaid rentals plus claim damages arising from that single breach of the lease contract.
- If the lessor files one complaint for the rentals from January to March, and later files another complaint for April to June (both for the same continuing violation of the same lease contract), this constitutes splitting a single cause of action (non-payment under one lease arrangement).
- The defendant can raise litis pendentia if both suits are pending or res judicata if judgment in one case has already attained finality, leading to the dismissal of the second suit.
Not Splitting Where Causes of Action are Different:
- If the lessor sues for the unpaid rentals in one action, and in another action sues for damages to the leased property caused by the tenant’s negligence (an entirely separate wrongful act), those are two different causes of action even if arising out of the same lease relationship.

6. Effects of Splitting a Single Cause of Action

Ground for Dismissal:
- The subsequent action or actions based on the same cause of action may be dismissed on the ground of litis pendentia (if the first action is still ongoing) or res judicata (if the first action is already terminated by a final judgment on the merits).
Waiver of Other Claims:
- Once final judgment is rendered in the first case covering part of the same cause of action, any remaining claims that should have been included in that case can no longer be pursued. They are barred by that final judgment.
Estoppel by Judgment / Res Judicata:
- The final judgment in the first suit bars subsequent suits on the same cause of action. The entire cause of action merges in or is extinguished by the judgment in the first suit.
Possible Liability for Costs or Sanctions:
- The party who splits a cause of action and files multiple suits without justification may be liable for litigation costs. In extreme or improper cases, it can invite sanctions for forum shopping.

7. Distinguishing from Joinder and Consolidation

Joinder of Causes of Action (Rule 2, Section 5):
- Permissive joinder of causes of action is the opposite of splitting: it allows a plaintiff to include multiple causes of action in one complaint if certain conditions are met (e.g., same parties, same venue, etc.).
- Joinder does not violate the rule against splitting a cause of action, because in joinder, the plaintiff is bringing different causes of action together in one complaint, not fragmenting a single cause of action.
Consolidation:
- Courts can consolidate actions involving common questions of law or fact to avoid multiplicity of suits. This is different from prohibiting splitting: consolidation merges separate actions into one proceeding for efficiency, whereas prohibiting splitting ensures a single cause of action is not severed across multiple suits.

8. Relevant Jurisprudence

Philippine American General Insurance Co. vs. Sweet Lines, Inc., 212 SCRA 194 (1992)
- The Supreme Court reiterated the doctrine against splitting a single cause of action, emphasizing that a party should bring, at one time, all the claims and reliefs arising out of the same transaction or occurrence.
Aquino vs. Court of Appeals, 256 SCRA 696 (1996)
- Held that a final judgment on the merits in the first suit is a bar to the subsequent suit involving the same parties and the same cause of action.
Other Cases
- Suarez vs. Villarama, Jr. (G.R. No. 164790, 2012) – Emphasizes that what is determinative is whether the cause of action in both suits is essentially the same, not merely whether the suits are labeled differently.

9. Practical Reminders and Legal Strategy

Drafting the Complaint:
- A lawyer must carefully identify all demands and remedies arising from a single cause of action and include them in a single complaint.
- Failing to do so risks waiving omitted claims if the first action reaches finality.
Defensive Measures:
- When facing multiple suits, defense counsel should immediately assess whether there is a single cause of action split across different suits.
- File a Motion to Dismiss on grounds of litis pendentia or res judicata where appropriate.
Avoiding Forum Shopping:
- Splitting a cause of action is closely related to forum shopping, which is prohibited. Counsel must ensure full disclosure if the party or counsel has filed or is filing multiple suits involving the same cause of action.
Exception – Different Causes of Action:
- If facts give rise to more than one violation of rights (i.e., more than one legally distinct cause of action), each may be pursued independently. The key is to ensure they are genuinely distinct wrongs.

10. Summary

Single Cause of Action: One right violated by one act or omission.
Splitting: Suing separately for different parts of that single cause of action or demands arising from that single right violation.
Prohibition: Rule 2, Section 3 & 4 of the Rules of Court prohibit splitting to avoid multiple suits, conflicting judgments, and undue harassment of defendants.
Legal Consequences: The second or subsequent suit is dismissible on litis pendentia or res judicata; any claims not asserted in the initial action are barred by final judgment.
Best Practice: Lawyers must include all possible reliefs and damages arising from a single cause of action in one complaint to comply with the Rules and avoid a bar to recovery.

This is the comprehensive framework on splitting a single cause of action and its effects under Philippine civil procedure. By adhering to these rules, litigants and counsel ensure procedural efficiency and uphold the policy against duplicative litigation.