Case Digest (G.R. No. L-34589)
Facts:
- Engineering Construction Inc. (ECI) filed a complaint for damages against the National Power Corporation (NPC) on August 29, 1968.
- ECI claimed that NPC's improper and careless opening of the spillway gates of Angat Dam during Typhoon "Welming" on November 4, 1967, caused flooding that damaged ECI's facilities and equipment.
- The trial court found NPC guilty of gross negligence on December 23, 1970, and awarded ECI various damages totaling P1,009,985.31.
- NPC filed a notice of appeal, but ECI was granted execution pending appeal upon posting a bond, which was later increased to P1,109,000.
- Deputy Sheriff Restituto R. Quemada garnished funds from MERALCO, which were due to NPC, to cover the judgment sum.
- NPC's attempts to lift the order of execution were unsuccessful, leading to a petition for certiorari with the Court of Appeals.
- The Appellate Court nullified the execution pending appeal and ordered restitution of the garnished funds.
- ECI and MERALCO filed separate petitions for review before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the execution pending appeal was valid only for the actual damages awarded to ECI but should have been postponed for consequential and exemplary damages and attorney's fees.
- The Suprem...(Unlock)
Ratio:
The Supreme Court emphasized that while Section 2, Rule 39 of the Rules of Court allows for execution pending appeal, it must be based on good reasons stated in a special order. The trial court's decision to grant execution pending appeal for actual damages was upheld because the documentary evidence supporting these damages was substantial and uncontested by NPC. However, the execution for consequential and exemplary damages and attorney's fees was deemed premature as these amounts are often subject to reduction or elimination upon appeal. The Court cited the case of RCPI vs. Lantin, which highlighted that execution of moral and exemplary damages should depend on the final resolution of the main case.
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Case Digest (G.R. No. L-34589)
Facts:
The case involves Engineering Construction Inc. (ECI) and the National Power Corporation (NPC), with the Court of Appeals as a respondent. On August 29, 1968, ECI filed a complaint for damages against NPC in the Court of First Instance of Manila, Branch 15. ECI alleged that its facilities and equipment were damaged due to the improper and careless opening of the spillway gates of Angat Dam by NPC during Typhoon "Welming" on November 4, 1967, which led to the inundation of ECI's campsite in Ipo, Norzagaray, Bulacan. On December 23, 1970, the trial court found NPC guilty of gross negligence and awarded ECI P675,785.31 in actual damages, P233,200.00 in consequential damages, P50,000 in exemplary damages, and P50,000 in attorney's fees. NPC filed a notice of appeal, but ECI moved for and was granted execution pending appeal upon posting a bond, which was later increased to P1,109,000. The trial court justified the execution pending appeal based on several grounds, including the substantial documentary evidence supporting the actual damages and the financial distress of ECI. Deputy Sheriff Restituto R. Quemada garnished funds from MERALCO, which were due to NPC, to cover the judgment sum. NPC's attempts to lift the order of execution were unsuccessful, leading to a petition for certiorari with the Court of Appeals. The Appellate Court nullified the execution pending appeal...