G.R. No. 121171 - Asset Privatization Trust vs. Court of Appeals

Republic Act Nos. 1828, 2077 and 4167 authorized Marinduque Mining and Industrial Corporation (MMIC) to explore and exploit minerals in Surigao Mineral Reservation.
Philippine government, through Surigao Mineral Reservation Board, backed MMIC’s financing via purchase of debentures, guarantees and commitments from PNB, DBP and foreign lenders up to US$100 Million.

On July 13, 1981, MMIC, PNB and DBP executed a Mortgage Trust Agreement covering all MMIC assets, with detailed Events of Default and foreclosure procedures.
MMIC’s loans and guarantees grew to ₱22,668,537,770.05 by mid-1984 and became overdue; efforts to implement a Financial Restructuring Plan (FRP) were drafted but not formally ratified by PNB/DBP.

Complying with PD 385, in August–September 1984 PNB and DBP foreclosed MMIC’s mortgages; PNB purchased the foreclosed assets.
Foreclosed assets were assigned to newly formed corporations and, in 1986, transferred to Asset Privatization Trust (APT).

On February 28, 1985, minority stockholders filed Civil Case No. 9900 for annulment of foreclosure, specific performance under FRP and damages against PNB and DBP.
In October 1992, parties entered into a Compromise and Arbitration Agreement:

Withdraw suit and convert all claims into pure money claims.
Submit two issues—capacity to sue derivatively and validity of foreclosure—to a three-member Arbitration Committee.
Court approved the compromise, substituted APT as defendant, transformed reliefs and dismissed the complaint.

On November 24, 1993, Arbitration Committee ruled foreclosure invalid and awarded MMIC ₱2.53 B actual damages, ₱13 M moral/exemplary damages, and ₱10 M moral damages to Cabarrus Sr., with offsets from MMIC’s debt. It declared its decision “final and executory.”
On October 17, 1994, MMIC filed an “Application/Motion for Confirmation” of the award in Civil Case No. 9900; APT opposed and moved to vacate the award.
On November 28, 1994, RTC Makati Branch 62 confirmed the arbitration award (increased actual damages to ₱3.81 B) and declared it final and executory.
APT’s December 27, 1994 motion for reconsideration was denied as tardy by order of January 18, 1995.
APT filed a Rule 65 certiorari petition with the CA, which on July 17, 1995 denied due course and dismissed the petition. APT elevated the case to the Supreme Court.

Did RTC Makati Branch 62 lose jurisdiction to confirm the arbitral award by dismissing Civil Case No. 9900?
Was APT estopped from questioning the arbitral award after seeking its vacation in the same case?
Should the motion for confirmation of award have been dismissed or should the court have entertained APT’s motion to vacate?
Did CA err in not treating APT’s Rule 65 petition as an appeal from the confirmation order?
When does the period to file a motion for reconsideration of a confirmation order begin to run?