G.R. No. 158332 - Maricalum Mining Corp. vs. Remington Industrial Sales Corp.

Maricalum Mining Corporation (petitioner) and Remington Industrial Sales Corporation (respondent) are embroiled in a dispute over the payment for construction materials and other merchandise amounting to P921,755.95.
The dispute originated from a complaint filed by respondent against Marinduque Mining and Industrial Corporation (Marinduque Mining), which was later amended to include several co-defendants such as Philippine National Bank (PNB), Development Bank of the Philippines (DBP), Nonoc Mining and Industrial Corporation, Asset Privatization Trust (APT), Island Cement Corporation, and petitioner Maricalum.
Petitioner was impleaded on the ground that it acquired the real and personal properties, machinery, equipment, and other assets of Marinduque Mining foreclosed by PNB and DBP.

On April 10, 1990, the Regional Trial Court (RTC) rendered a Decision ordering all defendants, including petitioner, to jointly and severally pay the principal obligation along with interest, attorney’s fees, and costs.
Petitioner and its co-defendants filed an appeal with the Court of Appeals (CA) under CA-G.R. CV No. 27720, which was dismissed on October 6, 1995.
Separate appeals were subsequently instituted by DBP and PNB.
Petitioner attempted to file an appeal by submitting a motion for an extension to file a Petition for Review on Certiorari; however, it was denied due to the lack of an affidavit of service, resulting in the motion’s rejection in the December 4, 1996 Resolution (finalized January 30, 1997).
Petitioner’s attempt to intervene in PNB v. CA was also disallowed on grounds of tardiness.

On December 5, 2000, respondent filed a Motion for Execution solely against petitioner, contending that, with the finality of the RTC Decision due to the earlier denial of petitioner’s motion for extension, a writ of execution should be issued.
The RTC issued an Order on March 9, 2001, granting the Motion for Execution, and later denied petitioner’s Motion for Reconsideration on May 10, 2001.
A Writ of Execution was executed, which led to the garnishment of certain bank accounts of petitioner.
In response, petitioner filed a Petition for Certiorari and Prohibition with the CA (docketed as CA-G.R. SP No. 65209), challenging the RTC Orders and seeking the dismissal of respondent’s claim.

The facts and issues in the cases of Development Bank of the Philippines v. Court of Appeals (DBP v. CA) and Philippine National Bank v. Court of Appeals (PNB v. CA) are cited as relevant to the present dispute.
In DBP v. CA, the Court addressed issues pertaining to the relationship between Marinduque Mining, DBP, and their transferees, including petitioner, and whether the piercing of the corporate veil was justified.
In PNB v. CA, the Court ruled that respondent had no valid cause of action against the banks and their transferees because the foreclosure sale and subsequent transfer of properties were legitimate and mandated by law (notably under Presidential Decree No. 385).

Asserting that petitioner, as merely an assignee/successor-in-interest of PNB and DBP, should not be held liable for the obligations arising from the original RTC Decision.
Holding that any vested rights acquired by respondent against petitioner, due to its participation in the foreclosure chain, were invalidated by the final decisions in DBP v. CA and PNB v. CA.

The petitioner stressed that the aforementioned Supreme Court decisions exonerated it from liability, as they clearly indicated that the obligations remained with Marinduque Mining and not with petitioner.

The Court explained that the failure of a party to perfect its appeal renders the judgment final and executory, thereby conferring vested rights to the winning party.
The execution of such a judgment, once final, is a ministerial duty, which supports the issuance of a writ of execution and the corresponding enforcement measures (such as the garnishment of bank accounts).

Whether the decisions in DBP v. CA and PNB v. CA, which were rendered against respondent Remington, should inure to the benefit of petitioner Maricalum who was not a party to those cases.

Does the finality of the DBP v. CA and PNB v. CA decisions bar the enforcement of the April 10, 1990 RTC Decision against petitioner?
Does the commonality of interests among the co-defendants allow petitioner to be bound by the appellate decisions even though it did not file its own appeal?

Whether petitioner, as an assignee/successor-in-interest of PNB and DBP, can be held liable for the debts of Marinduque Mining and any obligations imposed by the RTC Decision.

Is the allegation of acquiring vested rights on the part of respondent against petitioner justified?
How does the separation of corporate personalities affect the liability of petitioner given its status as a transferee?

Whether the issuance of the writ of execution, based on the RTC Decision that became final and executory against petitioner, was proper in light of subsequent Supreme Court rulings.