## **Facts:**
– **May 26, 1984**: Private respondents filed two complaints against petitioners in the Regional Trial Court (RTC) of Quezon City. The complaints were for injunction, specific performance, and damages.
– **December 16, 1987**: The RTC decided against the petitioners, finding that they defrauded the private respondents. Petitioners were held solidarily liable for P450,000 plus 15% interest and P30,000 as attorney’s fees.
– **February 1, 1988**: RTC amended its decision on consideration of motions to specify the amounts due to each complainant. On the same day, petitioners filed a notice of appeal.
– **February 7, 1988**: Private respondents received the amended decision and filed a motion for execution pending appeal six days later.
– **March 1988**: RTC Judge Filemon H. Mendoza granted the motion for execution pending appeal, noting the long duration of the case, the insolvency of the defendant bank, and the potential permanent relocation of defendant Renato Tuazon.
– **April 1988**: Petitioners challenged this order via certiorari in the Court of Appeals.
– **April 10, 1989**: The Court of Appeals sustained the RTC’s order, declaring the petition premature as the order and writ of execution had not yet been issued, and the bond sufficed for execution pending appeal.
– **May 11, 1988**: The formal writ of execution pending appeal was issued by the trial court on May 30, 1988.
– **Supreme Court**: Petitioners sought the Supreme Court’s intervention, questioning the justification for executing the decision pending appeal.
## **Issues:**
1. **Whether there was a valid justification for the trial court’s order granting execution pending appeal.**
2. **Whether the resolution denying the motion for reconsideration complied with constitutional requirements.**
## **Court’s Decision:**
### **Issue 1: Valid Justification for Execution Pending Appeal**
– The Supreme Court cited the general rule that a judgment can be executed only after it becomes final and executory (Sec. 1 of Rule 39), but acknowledged the exception under Sec. 2 for execution pending appeal given good reasons in a special order.
– **Rationale**: The RTC’s reasons for granting execution pending appeal included the potential inability of some defendants to satisfy the judgment, the insolvency of one defendant bank under receivership, and the permanent relocation of another defendant.
– The Court disagreed with the Court of Appeals that posting a bond alone was enough to justify execution pending appeal. It emphasized that posting a bond should not make execution pending appeal a routine process.
– The Supreme Court found the justifications given by the trial court adequate to consider them “good reasons” under Rule 39, Section 2, thus validating the RTC’s order.
### **Issue 2: Constitutional Compliance of Order Denying Reconsideration**
– The petitioners claimed that the resolution denying their motion for reconsideration by the appellate court did not comply with Article VIII, Sec. 14 of the Constitution.
– **Ruling**: The resolution stated it found “no cogent reason to justify the reversal,” which the Supreme Court deemed sufficient. The Court of Appeals essentially reaffirmed and sustained its decision without needing to restate all findings and conclusions.
## **Doctrine:**
– **Execution Pending Appeal**: Justification under Rule 39, Section 2 must consist of special, pressing reasons beyond posting a bond. The trial court retains discretion provided it articulates good reasons.
– **Retention of Jurisdiction**: A trial court maintains jurisdiction to act on motions for execution pending appeal within the 15-day appeal notice period.
## **Class Notes:**
– **Key Elements for Execution Pending Appeal (Rule 39, Sec. 2)**:
– Motion with notice to adverse party.
– Good reasons stated in a special order.
– Trial court discretion subject to articulation of reasons.
– **Constitutional Requirement (Article VIII, Section 14)**:
– Decisions must state clearly and distinctly the facts and law on which they are based.
– Simple affirmation of previous rulings can suffice for compliance.
## **Historical Background:**
– This case exemplifies the application of detailed procedural requirements for execution pending appeal within the Philippine judicial system, particularly illustrating checks against potential abuse of interim execution practices. It reflects sustained judicial caution against routine granting of execution pending appeal solely on bond posting, stressing material, case-specific contexts.
Leave a Reply