G.R. No. 176951 - League of Cities of the Philippines vs. Commission on Elections

On October 3, 1983, William Samara (private respondent) filed Civil Case No. 50248 before Branch 160 of the Regional Trial Court in Pasig, Metro Manila, against Citytrust Banking Corporation (petitioner) and Marine Midland Bank, N.A. (co-defendant).
The complaint alleged that private respondent purchased a US$40,000.00 demand draft from Citytrust which was intended for a joint venture with Tony Mancuso for bringing American entertainers to the Philippines.

The demand draft was drawn against Marine Midland in favor of Thai International Airways, reflecting the estimated cost for air transportation.
Sensing that Tony Mancuso would not fulfill his part of the agreement, private respondent executed a stop-payment order on December 23, 1980, and instructed Citytrust to notify Marine Midland through telex at once.
Both defendant banks confirmed non-payment of the draft, leading Citytrust to recredit private respondent’s dollar account with US$40,000.00.
Later, after a lapse of seven months, Citytrust debited the same account upon discovering that Marine Midland had already debited US$40,000.00 from its own account.

Private respondent filed a protest regarding the debit and demanded the return of the amount, also alleging that Tony Mancuso had left the Philippines, making recovery from him impossible.
Citytrust filed its answer with a counterclaim and cross-claim on January 4, 1984, while Marine Midland filed its respective pleadings on January 16, 1984.
On March 4, 1986, the Regional Trial Court rendered a judgment holding Citytrust and Marine Midland jointly and severally liable to private respondent, ordering:

Payment of US$40,000.00 with pre-judgment interest at 12% per annum from July 3, 1981, until full payment, plus further interest on accrued interest from December 23, 1980, up to the filing of the complaint;
Payment of exemplary damages of P100,000.00, attorney’s fees, and costs;
Reimbursement by Marine Midland to Citytrust for any amounts paid to the plaintiff by reason of this judgment and costs.

Petitioner (Citytrust) received a motion for reconsideration from Marine Midland on March 26, 1986, seeking reversal of the trial court decision on both banks’ liability.
Due to Citytrust’s failure to timely appeal the decision, private respondent filed a motion for execution on April 29, 1986, with Citytrust opposing it on May 7, 1986.
After receiving the order denying Marine Midland’s motion for reconsideration on May 5, 1986, Citytrust filed a Notice of Appeal on May 7, 1986.
The trial court eventually set aside the execution order to prevent potential injustice regarding reimbursement arrangements between Citytrust and Marine Midland pending resolution on appeal.
The issue advanced to the Court of Appeals where private respondent moved to dismiss the appeal. The appellate court granted the motion to dismiss on December 15, 1987, and denied Citytrust’s subsequent motion for reconsideration.

Whether the appeal of the petitioner’s co-defendant, Marine Midland, should benefit Citytrust by suspending its own appeal period.
Whether private respondent should be entitled to immediate execution of the final judgment even if Citytrust’s appeal was filed tardily.

Citytrust argued that Marine Midland’s motion for reconsideration was intended to equally benefit both defendants, citing the interdependency of their rights and liabilities due to cross claims.
However, it was noted that the actions and representations of the parties were independent, and the intermingling of liabilities was not sufficient to equate the appeal status between the two banks.

Whether the execution of a final judgment can be prevented on the ground that a co-defendant (Marine Midland) filed an appeal which, it is argued, should inure to the benefit of the non-appealing defendant (Citytrust).

Whether private respondent may immediately execute the final judgment even when one of the defendant banks (Citytrust) filed its appeal beyond the reglementary period, and regardless of the appeal status of its co-defendant.