Case Digest (G.R. No. 130757)
Facts:
Hon. Emilia T. Boncodin, in her capacity as Secretary of Budget and Management, petitioner, v. Court of Appeals, Angel Teves, Jr., Estaban Valencia, Jr., Vicente Sapio, Nemenciano Rubillos, Alberto del Mar, Leo de los Reyes and Terollo Bacalso, respondents, G.R. No. 130757, January 18, 2002, First Division, Pardo, J., writing for the Court.In January 1990 private respondents (municipal employees) filed a petition for mandamus in the Regional Trial Court (RTC), Cebu, against the City Government of Cebu, seeking implementation of Republic Act No. 6758 (Salary Standardization Law) retroactive to its effectivity on July 4, 1989. On June 13, 1990 the RTC ordered the City to enact a supplemental budget within 15 days to implement the salary increase retroactive to July 1, 1989. The City appealed to the Court of Appeals (docketed CA‑G.R. SP No. 22459).
While the appeal was pending the City enacted Supplemental Budget No. III (Ordinance No. 1373) covering July 1 to October 31, 1989. On October 21, 1993 the Court of Appeals affirmed the RTC decision; that judgment became final and executory on November 11, 1993. Private respondents moved for execution on July 5, 1995; the City opposed, asserting full compliance with RA 6758. The RTC issued an alias writ of execution on February 29, 1996 directing appropriation of P384,860,540.00 for full implementation of RA 6758.
The City sought certiorari in the Supreme Court (docketed G.R. No. 125439) to annullate various RTC orders; that petition was referred to the Court of Appeals (CA‑G.R. SP No. 41444). Meanwhile, on September 11, 1996 the Budget Secretary, Hon. Emilia T. Boncodin (petitioner here), filed a motion for leave to intervene in the Court of Appeals proceedings, asserting the DBM’s legal interest as administrator of the unified compensation and position classification system under RA 6758 and relying on Victorina Cruz v. Court of Appeals, G.R. No. 119155, January 30, 1996, for DBM’s exclusive administrative authority.
Private respondents opposed intervention; the City Government supported it. The Court of Appeals denied the motion for leave to intervene on April 21, 1997, holding that petitioner’s legal interest did not approximate the interest sufficient for intervention at that stage, and...(Pro-only)
Issues:
- May petitioner intervene at the execution stage of the judgment in CA‑G.R. SP No. 22459?
- Did the Court of Appeals act with grave abuse of discretion in denying petitioner’s motion for leave ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)