Title
Philippine Virginia Tobacco Administration vs. Delos Angeles
Case
G.R. No. L-30085-87
Decision Date
Dec 26, 1974
PVTA appealed a partial judgment on unpaid tobacco shipments, but the Supreme Court ruled its appeal moot due to voluntary execution of the judgment, upholding the trial court's decision.

Case Digest (G.R. No. L-30085-87)

Facts:

  • Background of the Case
    • The case involves the Philippine Virginia Tobacco Administration (PVTA) as petitioner and numerous private corporate respondents engaged in the production and sale of flue-cured Virginia tobacco.
    • The original action was a mandamus proceeding filed to compel the Judge of the Court of First Instance of Rizal, Quezon City (Branch IV), to set the hearing for the approval of PVTA’s record on appeal in Civil Cases Nos. Q-11547, Q-11578, and Q-11659.
    • The private respondents had initiated complaints on different dates in October 1967 alleging that PVTA, through its management contract with Farmers’ Virginia Tobacco Redriers, Inc. (FVTR), became liable for payments on tobacco shipments delivered by the respondents.
  • The Stipulation of Facts and Contractual Background
    • On December 13, 1967, during the pre-trial hearing, the parties submitted a detailed “Stipulation of Facts” which set forth key admissions including:
      • The existence of the juridical capacity of both parties.
      • The establishment of a management contract between PVTA and FVTR on April 29, 1963, under which FVTR was authorized to procure, redry, and service an allocation of two (2) million kilos of tobacco on behalf of PVTA.
    • Subsequent board resolutions of PVTA (such as Resolution Nos. 113, 131, 68, 236, 245, and 284) modified the tobacco procurement allocations, adding additional allocations but without executing new management contracts covering these additional amounts.
    • Various documentary evidences in the stipulation include several annexed “Stifacts” (A-K), which detailed:
      • The list of accepted tobacco shipments (Annex D-1) with an aggregate unpaid value of P377,418.69.
      • Special committee reports and related correspondence, including a letter reminding FVTR of conditions for additional allocations and a prepared form for tobacco shippers.
  • Acceptance of Shipments and Payment Instructions
    • Under the terms of the management contract, FVTR began accepting tobacco shipments for redrying and servicing, which included the shipments enumerated in the "Condensed List" (Annex D-1).
    • The shipments covered under Category I – within the original two-million kilo allocation – remained unpaid as of October 31, 1966, despite being acknowledged by PVTA management.
    • Additional shipments and allocations, though later granted by board resolutions, were not governed by a newly executed contract, thereby complicating the liability issue.
  • Partial Judgment and Subsequent Proceedings
    • On December 15, 1967, the trial court rendered a “Partial Judgment” based on the agreed Stipulation of Facts limiting its decision to the shipments noted in the stipulation.
      • The judgment ordered PVTA to pay specified sums with legal interest to various respondents for the shipments accepted by FVTR.
      • PVTA’s cross-claims against FVTR for unauthorized shipments were noted as being kept separate for later resolution.
    • PVTA subsequently filed a notice of appeal along with the necessary appeal bond and a record on appeal.
    • The plaintiff corporations moved to strike out this Notice of Appeal, arguing that the partial judgment was essentially a judgment by confession or compromise and that PVTA had already benefited from it.
  • Motion to Reconsider and Joint Motion for Suspension
    • On January 17, 1968, the trial court dismissed PVTA’s appeal by striking the Notice of Appeal and Record on Appeal from the record.
    • PVTA filed a motion to reconsider, contending that:
      • The stipulation of facts was not a compromise nor a confession of liability.
      • The judgment’s computation of attorney’s fees and interest was in error.
      • Dismissing the appeal deprived them of a substantive right without due process.
    • A joint motion by the parties sought the suspension of the running of the appeal period against the multiplicity of partial judgments, which was later denied by the court on November 21, 1968, on the ground that the appeal period could not be suspended by judicial order.
  • Final Developments
    • It is uncontested that PVTA accepted benefits under the partial judgment, including payments for merchandising loans.
    • The execution of the partial judgment and the acceptance of its benefits by PVTA became central to the subsequent ruling on its appeal.

Issues:

  • Whether the partial judgment rendered on the basis of the agreed Stipulation of Facts, which PVTA later accepted in form of payment and benefits, can be validly appealed.
    • The specific issue centers on whether the acceptance and execution of the judgment bars further appellate review.
  • Whether the computation of attorney’s fees and the interest from the specified dates (48 hours after certain shipments were accepted) are factually and legally correct.
  • Whether the Stipulation of Facts should be construed as a compromise or a judgment by confession, thus precluding PVTA from questioning it on appeal.
  • Whether the trial court’s dismissal of PVTA’s appeal on the grounds of the judgment’s execution and the voluntary acceptance of its benefits constitutes grave abuse of discretion or an excess of jurisdiction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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