Case Digest (G.R. No. 103590) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Government Service Insurance System (GSIS) vs. Court of Appeals, G.R. No. 103590, decided January 29, 1993, the GSIS contracted with *Queen’s Row Subdivision, Inc.* (QRSI) to finance the construction of 4,493 housing units in Molino, Bacoor, Cavite, for GSIS members. QRSI engaged Victor G. Valencia to perform certain land‐development phases under a separate construction contract. After Valencia completed his work, QRSI refused payment, prompting Valencia to file Civil Case No. BCV-78-33 in the Regional Trial Court (RTC) of Bacoor, Cavite, claiming P755, (etc.) with interest and attorney’s fees and praying for a writ of preliminary attachment. The trial court rendered judgment on March 2, 1982 in favor of Valencia, awarding him specific sums and ordering QRSI to pay, and further directing GSIS “to hold whatever amounts it has granted to, retained and obtained for defendant Queen’s Row… and to deliver same to plaintiff…,” clarifying that GSIS “shall not be personally liable” be Case Digest (G.R. No. 103590) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contractual Background
- Queen’s Row Subdivision, Inc. (QRSI) entered into a financing agreement with the Government Service Insurance System (GSIS) to develop and sell 4,493 housing units in Molino, Bacoor, Cavite.
- QRSI subcontracted private respondent Victor G. Valencia for various phases of land development.
- Trial Court Proceedings (RTC, Civil Case No. BCV-78-33)
- Valencia completed work, demanded payment; QRSI refused → Valencia sued QRSI and GSIS for sums due, with preliminary attachment.
- RTC Decision (2 March 1982) awarded Valencia P448,374.01, P204,821.32, P102,866.37 plus interest and attorneys’ fees; ordered GSIS to hold and deliver any funds retained for QRSI to Valencia, but not to be personally liable beyond those funds.
- Post-Judgment Execution and Garnishment
- Valencia obtained execution writs; GSIS partially paid P154,476.14 in November 1982; further alias writs and garnishment notices issued against GSIS and PNB.
- RTC Orders (5 July 1985, 22 May 1986) compelled GSIS to pay remaining judgment, rejecting GSIS’s claim of QRSI debt to GSIS. GSIS motions for reconsideration denied.
- Court of Appeals and Supreme Court in Prior Litigations
- CA (CA-G.R. SP No. 09956) dismissed GSIS’s certiorari petition, holding RTC decision final and GSIS’s legal compensation defense waived by partial payment.
- SC (G.R. No. 87980) denied review, affirming finality of RTC decision and application of PD 1594 on retentions.
- Subsequent RTC Execution Orders
- Order of 7 June 1990: GSIS to pay Valencia P2,567,374.06 (12% per annum simple interest) or face alias writ.
- Supplemental Order of 10 September 1990: compounded interest 12–21% per annum per various Central Bank circulars, total due P11,363,304.27 less prior payment.
- RTC denied reconsideration (5 December 1990).
- CA Petition in CA-G.R. SP No. 24021
- GSIS filed certiorari and prohibition, challenging RTC orders of June, September, December 1990 as varying RTC decision tenor.
- CA Decision (28 June 1991): set aside those orders; remanded to determine funds GSIS holds for QRSI (liability limit).
- CA Resolution (15 January 1992): granted Valencia’s motion, reversed 28 June 1991 decision on grounds of res judicata and estoppel; dismissed GSIS petition.
- Present SC Petition for Review (Rule 45)
Issues:
- Whether the Court of Appeals correctly held GSIS’s certiorari petition (CA-G.R. SP No. 24021) barred by prior judgments (res judicata) and estoppel.
- Whether the CA erred in reversing its own June 28, 1991 decision reinstating GSIS’s limited liability under the RTC decision.
- Whether the RTC orders of June 7, 1990 and September 10, 1990 impermissibly varied the tenor of the RTC decision by imposing 12–21% interest and attorneys’ fees on GSIS.
- Whether GSIS’s liability is properly limited to the funds “granted to, retained and obtained” for QRSI, and whether the legal interest rate under Article 2209 (6% per annum) applies instead of Central Bank circular rates.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)