Case Digest (G.R. No. 172892)
Facts:
Government Service Insurance System v. Hon. Court of Appeals, G.R. No. 103590, January 29, 1993, Supreme Court Third Division, Davide, Jr., J., writing for the Court.Several years before the litigation, Queen’s Row Subdivision, Inc. (QRSI) entered into a construction project agreement with GSIS, under which GSIS financed development of a Molino, Bacoor subdivision; QRSI contracted with Victor G. Valencia (private respondent) to perform land development work. After Valencia completed his contract, QRSI refused payment and Valencia sued QRSI and GSIS in Civil Case No. BCV-78-33, claiming sums due and asking for a writ of preliminary attachment. Valencia did not seek relief against GSIS’s personal funds and presented his evidence; GSIS and QRSI offered no evidence.
On 2 March 1982 the trial court rendered judgment for Valencia, awarding specified monetary sums and including a dispositive clause (paragraph 3) requiring GSIS “to hold whatever amounts it has granted to, retained and obtained for defendant Queen’s Row, and to deliver same to plaintiff by way of payment” while expressly declaring GSIS “shall not be personally liable for the said obligation of co-defendant Queen’s Row, except, as herein above-ordered.” Valencia moved for execution pending appeal; GSIS made a partial payment of P154,476.14 on 26 November 1982 but did not appeal the March 1982 decision.
Execution proceedings followed. The trial court ordered GSIS to pay sums covered by writs; writs of execution and garnishments were issued against GSIS and the Philippine National Bank. In an order of 5 July 1985 the trial court held GSIS was holding funds for QRSI and directed payment to the judgment creditors; GSIS’s motion for reconsideration was denied on 22 May 1986. GSIS sought relief in the Court of Appeals by certiorari in CA-G.R. SP No. 09956; the Court of Appeals dismissed GSIS’s petition in a decision promulgated 17 April 1986, finding the March 1982 decision had become final and executory and that GSIS had acquiesced to the court’s order by failing to appeal and by making partial payment. GSIS sought review in the Supreme Court via Rule 45 (G.R. No. 87980), which the Court denied in a Resolution of 27 November 1989; the motion for reconsideration was denied 15 January 1990.
Subsequently, Valencia sought execution of a larger aggregate judgment. The trial court, by order of 7 June 1990, directed GSIS to deposit or pay specified amounts with computed interest (presented in the order as monthly 1% or 12% p.a.) and attorney’s fees; a Supplemental Order of 10 September 1990 fixed the total amount at P11,363,304.27 by applying compound interest rates allegedly based on several Central Bank circulars (12%–21% p.a. ceilings); the trial court denied GSIS’s motion for reconsideration on 5 December 1990.
GSIS filed a petition for certiorari and prohibition in the Court of Appeals (CA-G.R. SP No. 24021) challenging the trial court orders of 7 June 1990, 10 September 1990 and 5 December 1990 as varying the March 1982 judgment. On 28 June 1991 the Court of Appeals (per De Pano, J.) set aside the trial court orders and remanded for inquiry into how much funds GSIS actually holds for QRSI, reasoning that execution must conform to the dispositive judgment and GSIS’s liability was limited to funds it held for QRSI.
Valencia moved for reconsideration in the Court of Appeals, arguing the petition was barred by prior judgment and estoppel (citing CA-G.R. SP No. 09956 and the Supreme Court’s denial in G.R. No. 87980) and noting GSIS’s partial payment under the earlier order. On 15 January 199...(Subscriber-Only)
Issues:
- Did the Court of Appeals err, as a procedural matter, in holding that CA-G.R. SP No. 24021 was barred by prior judgment and estoppel?
- Did the Court of Appeals err in reversing its own June 28, 1991 Decision by granting reconsideration?
- Did the trial court act without or in excess of jurisdiction or with grave abuse of discretion in directing GSIS to pay interest at rates derived from Central Bank circulars (12%–21% p.a.) and attorney’s fees in executing the March 1982 judgment?
- Is GSIS estopped from disputing th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)