Case Digest (G.R. No. 74975)
Facts:
The case involves Tomasa L. Belgado, acting as the administratrix of the estate of the late Amada T. Laiz, as the petitioner, against the Intermediate Appellate Court, Francisco Laiz, Remedios Laiz, and Laiz Development Corporation as respondents. The events leading to this case began on September 1, 1984, when the Regional Trial Court of General Santos City, Branch XXIII, rendered a decision in favor of the petitioner in an action for annulment with damages. The court declared the Deed of Absolute Sale and the Deed of Conveyance of Real Properties, which were the subjects of the annulment action, as null and void. The decision also ordered the defendants to deposit the rentals and/or income from the properties in question to the court upon receipt of the decision. The private respondents received the decision on September 25, 1984, giving them until October 10, 1984, to file an appeal. On October 2, 1984, the private respondents filed a Notice of Appeal. Meanwhile, the petit...
Case Digest (G.R. No. 74975)
Facts:
Parties Involved:
- Petitioner: Tomasa L. Belgado, in her capacity as administratrix of the estate of the late Amada T. Laiz.
- Respondents: The Intermediate Appellate Court, Francisco Laiz, Remedios Laiz, and Laiz Development Corporation.
Case Background:
- The case originated from an action for annulment with damages filed by the petitioner against the private respondents.
- The Regional Trial Court (RTC) of General Santos City rendered a decision on September 1, 1984, declaring the Deed of Absolute Sale and the Deed of Conveyance of Real Properties null and void.
- The RTC also ordered the private respondents to deposit the rentals and/or income from the properties subject of the case into the court from the date of filing.
Timeline of Events:
- Private respondents received the decision on September 25, 1984, and had until October 10, 1984, to appeal.
- On October 2, 1984, private respondents filed a Notice of Appeal.
- Petitioner received the decision on October 1, 1984, and had until October 16, 1984, to appeal.
- On October 11, 1984, petitioner filed a Motion for Immediate Partial Execution pending appeal, seeking enforcement of the order to deposit rentals.
Trial Court’s Actions:
- The Trial Court initially denied the motion for execution pending appeal, citing loss of jurisdiction due to the perfection of the private respondents' appeal.
- Later, the Trial Court reconsidered, interpreting the order to deposit rentals as an order of accounting, which is not stayed by an appeal under Section 4, Rule 39 of the Rules of Court.
- On January 11, 1985, the Trial Court issued an order requiring lessees to deposit rentals in court.
Appellate Court’s Decision:
- The Intermediate Appellate Court ruled that the Trial Court’s orders were devoid of legal justification, as the judgment directing the deposit of rentals was not an order of accounting under Section 4, Rule 39.
- The Appellate Court held that the appeal was perfected on October 10, 1984, and the Trial Court lost jurisdiction when petitioner filed the motion on October 11, 1984.
- The Appellate Court allowed private respondents to withdraw the deposited rentals.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Perfection of Appeal:
- Under Section 23 of the Interim Rules, the perfection of an appeal is determined by the expiration of the last day to appeal by any party.
- In this case, the last day to appeal was October 16, 1984 (petitioner’s deadline), not October 10, 1984 (private respondents’ deadline).
- Therefore, the appeal was not perfected until October 16, 1984, and the Trial Court retained jurisdiction when the petitioner filed the motion on October 11, 1984.
Jurisdiction Over Execution Pending Appeal:
- The Trial Court had jurisdiction to act on the motion for execution pending appeal because the appeal was not yet perfected.
- The Supreme Court emphasized that allowing a party to deprive the adverse party of the right to move for execution pending appeal by immediately perfecting an appeal would be unjust.
Nature of the Order to Deposit Rentals:
- The Supreme Court did not explicitly rule on whether the order to deposit rentals constituted an order of accounting under Section 4, Rule 39.
- Instead, it focused on the jurisdictional issue and remanded the case for further determination on the merits of the motion for execution pending appeal.
Conclusion:
The Supreme Court clarified the interpretation of Section 23 of the Interim Rules, emphasizing that the perfection of an appeal is determined by the last day to appeal by any party. It also upheld the Trial Court’s jurisdiction to act on motions filed before the expiration of the appeal period.