G.R. No. L-38062 - Alto Sales Corp. vs. Lood

In a purchase agreement involving Virginia leaf tobacco, Alto Sales Corporation claimed that the Philippine Virginia Tobacco Administration (PVTA) breached the contract.

On May 3, 1968, Judge Andres Reyes, in Civil Case No. 10001, ordered PVTA to pay damages exceeding thirty-two million pesos to Alto for the breach.

Later, a subsequent trial emerged where Judge Guardson R. Lood reversed Judge Reyes’s decision.

On April 8, 1974, after a new trial, Judge Lood dismissed Alto’s complaint and absolved PVTA of any liability.

Judge Lood found that Alto had itself breached the agreement by failing to secure the necessary export license from the Central Bank.

Following Judge Lood’s decision, Alto Sales Corporation appealed the ruling with the Court of Appeals, and this appeal was docketed as CA-G.R. No. 57514-R on October 18, 1974.

Approximately three months before Judge Lood’s decision, on January 18, 1974, Alto filed a certiorari and mandamus petition to enforce Judge Reyes’s earlier award.

Alto contended that Judge Lood erred in granting a new trial because Judge Reyes’s decision had already attained finality and executory status.

Previously, on December 9, 1970, Judge Lood had set aside Reyes’s decision and granted a new trial, which Alto later challenged via a certiorari petition on April 3, 1971; however, that petition was dismissed as premature.

During the pendency of these proceedings, the new trial proceeded fully, and Judge Lood rendered his judgment less than three months later after the commencement of the new trial.

Respondents: Judge Guardson R. Lood representing the trial court decisions and the Philippine Virginia Tobacco Administration (PVTA).

The Solicitor General, acting as counsel for PVTA, provided this Court with a copy of Judge Lood’s decision.

The Court of Appeals became involved as the appellate forum where Alto’s appeal was docketed, and later, its record was required to be elevated to this Court for consolidation.

On August 10, 1981, with the consent of the parties, this Court resolved to elevate the record of CA-G.R. No. 57514-R and consolidate it with the certiorari and mandamus case.

Despite arguments by the Solicitor General for outright dismissal in favor of the appellate proceeding, the Court recognized that both matters were interrelated.

On January 30, 1984, following a motion by Alto for immediate resolution of both the certiorari/mandamus petition and its appeal, the Court reconsidered its earlier resolution.

Acting in the interest of the orderly administration of justice, the Court resolved to set aside its August 10, 1981 decision and returned the appellate record (with briefs) to the Intermediate Appellate Court for the immediate resolution of Alto’s appeal.

Whether Judge Lood erred in setting aside Judge Reyes’s decision, which Alto contended had already become final and executory.
Whether the certiorari and mandamus petition filed by Alto, in light of its pending appeal before the Court of Appeals, should be dismissed as moot or properly consolidated with the appeal.
Whether the factual findings made during the new trial by Judge Lood, particularly regarding Alto’s alleged failure to obtain the requisite export license, should be re-examined by the appellate court.
How to address the revival of issues previously raised in the 1971 certiorari petition, which was dismissed for premature filing, in the context of the consolidated proceedings.
The proper allocation of jurisdiction between the Supreme Court and the Court of Appeals, especially concerning fact-finding versus questions of law.