G.R. No. 89265 - Eudela vs. Court of Appeals

Two complaints were filed by the private respondents against the petitioners for injunction, specific performance, and damages in the Regional Trial Court (RTC) of Quezon City.
These complaints were consolidated and, after trial, a decision was rendered against the petitioners on December 16, 1987, holding them to be solidarily liable for defrauding the private respondents.
The decision imposed a collective liability amounting to P450,000.00 plus 15% interest and an additional P30,000.00 for attorney’s fees.

Both parties filed motions for reconsideration, leading to an amendment in the decision on February 1, 1988, which clarified the specific amount due to each complainant.
On the same day of the amended decision, the petitioners filed a notice of appeal from the original decision.
The private respondents, having received a copy of the amended decision on February 13, 1988, filed a motion for execution pending appeal six days later.

Judge Filemon H. Mendoza of the RTC of Quezon City issued an order granting execution pending appeal, admitting Exhibits “A” to “C” as part of the evidence supporting the motion.
The order was based on several material and supervening circumstances including:

The considerable delay from filing (May 26, 1984) to decision (December 16, 1987, and February 1, 1988) generating uncertainty about the petitioners’ capability to satisfy the judgment.
The defendant bank being under receivership and insolvency, raising concerns about the availability of its assets.
The likelihood of defendant Renato Tuazon staying abroad permanently and the disposition of his real properties through sale.

The order further provided that the private respondents must post a bond of P100,000.00 to cover potential damages resulting from the execution, should the appellate decision be reversed.

The petitioners challenged the RTC order by filing a petition for certiorari under Rule 45, arguing that there was no valid justification for granting execution pending appeal and that the denial of the motion for reconsideration did not comply with constitutional requirements.
The Court of Appeals found the petition to be premature since at the time of filing the petition, the order and the corresponding writ of execution had not been formally issued.
The appellate court underscored that the posting of the bond was a sufficient reason for the interim execution of the decision pending appeal.
The court also clarified that the trial court did not lose jurisdiction over motions for execution pending appeal merely upon the filing of a notice of appeal, as the records had not been transmitted to the appellate court.

The trial court’s decision and order were discussed in light of established jurisprudence regarding execution pending appeal, particularly under Section 2 of Rule 39 of the Rules of Court.
Relevant cases such as Cuento vs. Pareres and Roxas vs. Court of Appeals were cited to illustrate that the filing of a notice of appeal does not divest the trial court of its power to grant such execution, provided the motion is filed within the prescribed period and backed by “good reasons.”
The trial court’s order was thus seen as an exercise of its sound discretion, justified by the “good reasons” arising mainly from the risk that the petitioners (as solidary debtors) might not satisfy their obligations if their financial condition deteriorated further.

Whether the trial court’s order granting execution pending appeal was valid under the rules and principles governing execution pending appeal.
Whether the order was supported by sufficient “good reasons” as required by Section 2 of Rule 39 of the Rules of Court.

Whether the filing of a notice of appeal deprived the trial court of its jurisdiction to act on the petition for execution pending appeal.
Whether the continued possession of the case records by the trial court justified its ability to grant the motion.

Whether the resolution denying the petitioners’ motion for reconsideration complied with the constitutional requirement of stating a sufficient legal basis, particularly as mandated by Article VIII, Section 14 of the Constitution.
Whether the extensive pleadings by the petitioners introduced irrelevant discussions that might have led to a cluttered record, thereby affecting the administrative process of justice.