G.R. No. 65935 - Filinvest Credit Corp. vs. Intermediate Appellate Court

The case involves Filinvest Credit Corporation (petitioner) and Nestor B. Sunga, Jr. (private respondent), a businessman and owner of NBS Machineries Marketing and NAP-NAP Transit.
Filinvest Credit Corporation filed a special civil action for certiorari challenging decisions of the Intermediate Appellate Court (now Court of Appeals) and the trial court.

On March 21, 1978, Nestor Sunga, Jr. purchased a passenger minibus Mazda from Motorcenter, Inc. in Calasiao, Pangasinan.
To finance the purchase, Sunga executed a promissory note for Php62,592.00, payable in 24 monthly installments starting May 1, 1978.
Concurrently, he executed a chattel mortgage in favor of Motorcenter, Inc. which was later assigned to Filinvest Credit Corporation with his consent.

On October 21, 1978, two employees of Filinvest, under the instruction of Branch Manager Gaspar de los Santos, seized the minibus without issuing a receipt.
The seizure was allegedly based on an assertion of delinquency in the payment of the vehicle’s installment, although subsequent verification revealed the accounts were in order.
The minibus was later recovered from the Crisologo Compound after intervention by the police and admissions from Filinvest personnel.

A damage suit was filed by Sunga, and the trial court rendered a decision awarding him:

Moral damages of Php30,000.00;
Loss on income (Php600.00 for three days);
Actual damages (Php500.00);
Litigation expenses (Php5,000.00);
Attorney’s fees (Php10,000.00).

Dissatisfied with the trial court decision, Filinvest appealed.
On September 30, 1983, the Intermediate Appellate Court affirmed the trial court’s decision, but increased the moral damages to Php50,000.00.
After an unsuccessful reconsideration through the Resolution dated December 16, 1983, Filinvest petitioned for certiorari alleging grave abuse of discretion.

Ignored the errors assigned in its brief.
Decided on issues that were neither raised at trial nor on appeal.
Exceedingly and arbitrarily increased the award of moral damages.
Relied on a pending legislative measure (Batasan Bill No. 3075) and a non-doctrinal case (Rebosura) to support its decision.

The petitioner argued that these acts amounted to a lack of jurisdiction and denial of due process.

Failing to consider the assigned errors pointed out by Filinvest in its brief.
Resolving issues that were not raised in the trial court proceedings or on appeal.
Increasing the award of moral damages from Php30,000.00 (as determined by the trial court) to Php50,000.00 without jurisdiction.
Relying on non-doctrinal jurisprudence (Rebosura case) and a pending Bill (Batasan Bill No. 3075) to justify its decisions.

Whether the appellate court’s conduct constituted an overreach of its authority resulting in a palpable, arbitrary, and unconscionable award.