Facts:

The case involves Manuel M. Antonio as the plaintiff and appellant against Mauro Samonte and Mely Samonte, who are the defendants, alongside the National Waterworks and Sewerage Authority (NAWASA), serving as the petitioner and appellee. The dispute arose from a civil case (Civil Case No. 50846) filed by Antonio on June 8, 1957, in the Municipal Court of Manila, seeking recovery of money owed to him by the Samonte spouses. After the trial proceeded in default due to the absence of the defendants, judgment was rendered on June 25, 1957, in favor of Antonio, awarding him P915.00 plus interest. Following the judgment's finality, a writ of execution was issued against the Samonte spouses on August 1, 1957, but this writ was returned unsatisfied. Subsequently, on September 5, 1957, the sheriff levied on amounts owed to Samonte by NAWASA, after which NAWASA, despite being notified of the garnishment, paid Samonte a total of P6,527.33. Upon a motion filed by Antonio on March 1, 195

...

Facts:

Parties and Litigation Background

• Manuel M. Antonio, the plaintiff and appellant, initiated a case against the spouses Mauro Samonte and Mely Samonte (judgment debtors).
• The National Waterworks and Sewerage Authority (NAWASA), creditor of the judgment debtor, is involved as petitioner-appellee concerning its claims over Samonte’s credits.

Judgment and Execution of the Default

• In Civil Case No. 50846 of the Municipal Court of Manila, filed on June 8, 1957, a judgment by default was rendered on June 25, 1957 in favor of Antonio for P915.00 plus interest.
• A writ of execution, issued on August 1, 1957, was taken by the Sheriff of Manila, targeting the credits of the judgment debtor held by NAWASA.
• Despite receipt of a notice of garnishment, NAWASA subsequently disbursed a total of P6,527.33 to Samonte.

Examination of Credits and the April 10, 1958 Order

• On March 1, 1958, Antonio filed a motion requesting an examination of NAWASA, which revealed the existence of credits worth P1,377.00 in its possession, owed to Samonte.
• Based on this finding, the Municipal Court, through an order dated April 10, 1958, directed NAWASA to pay Antonio the sum of P992.25 (judgment credit plus interest).
• At that time, NAWASA did not raise any objection regarding the order.

NAWASA’s Petition and the May 10, 1958 Order

• On April 21, 1958, NAWASA filed a petition alleging the discovery of prior claims against Samonte’s credits, particularly for unpaid wages for services rendered under its contracts. These wage claims amounted to P3,853.50, in addition to other claims.
• NAWASA prayed that the April 10, 1958 order be set aside, requesting additional time to determine the exact amount due to defendants once the rights of prior claimants were satisfied.
• On May 10, 1958, the Municipal Court, finding merit in NAWASA’s petition, issued an order granting the petition. Though it stated that the April 10 order was to be withheld “for the time being,” the order effectively prioritized payment of NAWASA’s collated claims over Antonio’s judgment credit.

Subsequent Developments and Appeal

• The order of May 10, 1958 was appealed to the Court of First Instance of Manila, which dismissed it on December 26, 1958 as interlocutory and therefore unappealable.
• Antonio’s subsequent motion for reconsideration was denied on January 31, 1959, leading to the present appeal focusing solely on the finality and appealability of the May 10, 1958 order.

Issue:

• Whether the order of the Municipal Court dated May 10, 1958, which withheld the execution of the plaintiff’s judgment and prioritized NAWASA’s claims, constitutes a final order and is therefore appealable.

• Whether the characterization of the order as merely “for the time being” renders it interlocutory, or if its net effect is the conclusive adjudication of the substantial rights and priorities of the parties involved.

• Whether awaiting a further ruling by the Municipal Court on Antonio’s claim would jeopardize his rights by risking exhaustion of the funds through the satisfaction of NAWASA’s prior claims.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)