G.R. No. 206880 - People vs. Miranda, Jr. y Pana

On February 17, 1995, the Regional Trial Court (RTC) rendered a judgment in Civil Case No. Q-89-3580.
The judgment ordered Traders Royal Bank (TRB) and Security Bank and Trust Company to pay actual damages, exemplary damages, and attorney’s fees to the plaintiffs: Radio Philippines Network (RPN), Intercontinental Broadcasting Corporation (IBC), and Banaahaw Broadcasting Corporation (BBC).
Specifically, TRB was condemned to pay a total of ₱9,790,716.87, broken down among RPN (₱4,155,835.00), IBC (₱3,949,406.12), and BBC (₱1,685,475.75), plus interest.
The RTC also directed that Security Bank, as the collecting bank, reimburse TRB for any payments made to the plaintiffs, with each plaintiff also receiving ₱300,000.00 for exemplary damages and attorney’s fees amounting to twenty-five percent of the total recovery.

Traders Royal and Security Bank appealed the RTC decision; the Court of Appeals (CA) absolved Security Bank and held TRB solely liable.
Traders Royal elevated the case to the Supreme Court (G.R. No. 138510).
Separately, Traders Royal and Bank of Commerce (BankCom) executed a Purchase and Sale Agreement (PSA), conditioned by the Bangko Sentral ng Pilipinas to establish a ₱50,000,000.00 escrow fund for 15 years.
Traders Royal deposited the required amount with Metropolitan Bank and Trust Co. (Metrobank).

After the RTC’s judgment became final and executory in April 2003, plaintiffs proceeded with motions before the RTC to issue a writ of execution and subpoena duces tecum.
On March 31, 2004, the RTC issued a subpoena directing Metrobank to submit a detailed report regarding the escrow fund, which then revealed that the fund had been depleted.
A subsequent subpoena required BankCom to produce a list of Traders Royal’s assets and liabilities and directed Metrobank to produce documents on withdrawals from the escrow fund.
BankCom and Metrobank moved to quash the subpoena.
On August 15, 2005, the RTC, through an order of execution, directed that the judgment be executed against all of TRB’s assets, including those involved in the PSA and/or the escrow fund maintained with Metrobank.

Metrobank filed a Motion for Clarification and/or Reconsideration Ad Cautelam, asserting that it was not a party to the case and challenging the RTC’s authority to execute against it.
Metrobank argued that any proceeding directed at the escrow fund should be conducted separately.
On February 22, 2006, the RTC upheld its order of execution, clarifying that the escrow account was merely one of the possible sources to satisfy the award and that the RTC retained jurisdiction to resolve factual issues related to execution.

Dissatisfied with the RTC’s actions, BankCom and Metrobank filed petitions for certiorari before the CA (docketed as CA-G.R. SP Nos. 91258 and 94171).
The CA dismissed the petitions, ruling that the RTC did not act with grave abuse of discretion in directing execution against the escrow fund, as the depletion of the fund was properly within the RTC’s resolving power during execution.
Metrobank, however, questioned the RTC’s jurisdiction over its person and maintained that any action involving the escrow fund should be in a separate proceeding.

Whether the RTC properly ordered the execution of the money judgment against all assets, including the escrow fund held by Metrobank, without following the precise procedural requirements under the Rules of Court.

Is the RTC’s exercise of jurisdiction over Metrobank, as the escrow agent for TRB, valid in enforcing the judgment?
Did the RTC depart from the prescribed process under Section 9, Rule 39 of the Revised Rules of Court by not confining the order of execution exclusively to the judgment debtor’s own properties?

Whether the proper method for executing a money judgment—including the mandatory demand for immediate payment from the judgment debtor and resorting to levy only when such payment cannot be rendered—was observed.

Should the execution against the escrow fund require a separate proceeding or issuance of a writ of garnishment before Metrobank’s assets can be affected?
How does the RTC’s approach align with or deviate from established jurisprudence and procedural rules regarding garnishment and levy of a judgment debtor’s assets?