(Note: This brief is a best effort by a non-attorney (in Philippines or anywhere else). It also is just "in case", "if ever" needed. It's unlikely to ever be needed, one would hope. But, multiple people brought this possibility to me, so I will save this in case I need it in a hurry, to challenge some ridiculous attempt to further subvert the Philippine judicidial system. The facts it relies on have not yet come to pass, and hopefully never will. Jim Watkins has not refiled and has not done forum shopping to my knowledge as of 13 June 2020. Thus, why there are XXX's.)
Petitioner Jim Watkins continues to further constipate a constipated court system with his frivolous citizenship petitions which are utterly devoid of merit. This behavior, especially during the COVID-19 pandemic, is extraordinarily reckless. Why should petitioner Watkins get two cases in Court, after withdrawing his first, when many Filipinos have not even been heard once on much more urgent petitions?
As the Supreme Court has repeatedly declared, inter alios, in Municipality of Taguig vs. Court of Appeals and Barangay Hagonoy (G.R. No. 142619, 2005) and Daswani vs. BDO and Register of Deeds of Makati (G.R. No. 190983, 2015), it is "forum shopping" under Rule 7, Section 5 of the Revised Rules of Court to re-file a petition before another sala after an adverse ruling.
I argue that an adverse decision has already been reached in the case of In re: Naturalization Petition, OSG v. James Arthur Watkins (R-PSG-18-03091-SP, Pasig RTC Branch 166). I remind the honorable Court that it is not a defense against forum shopping to argue that the petitions were filed successively; to acheive a dismissal in one, especially at one's own request, then immediately, (XXX months later,) file in another sala, is also "forum shopping". The Court instructs in Daswani (G.R. No. 190983, 2015) that petitions may fall afoul of the anti-"forum shopping" rule whether or not they are "simultaneous" (the opposite being "successive"), and this is not the main criteria used, either by the Court, or by its duly enacted Rules of Court.
It cannot be argued that Hon. Quinagoran's ruling in R-PSG-18-03091-SP that I am a valid oppositor (intervenor), and have legal standing (locus standi), despite the various spurious defects his attorneys tried to argue at the time, (including the preposterous notion that pro se representation is invalid in the Philippines,) was anything but adverse to petitioner Watkins.
The court should dismiss this case with prejudice and carefully consider whether or not to charge him with indirect contempt of court as the aforementioned Rule 7 allows, as clearly the required declaration he made (pursuant to A.C. 04-94-SC, Annex XXX of petition XXX) that he's not engaging in forum shopping is false.
(NOTE: REMEMBER TO REPLACE XXX's.)