Facts:

• On April 27, 1990, Rogelio R. Coquial filed a complaint against the Province of Pangasinan and its Provincial Governor Rafael M. Colet before the RTC of Quezon City (Civil Case No. 0-90-5337).
• Coquial claimed a contract was made for the improvement of 6.492 kilometers of the Urdaneta-Mapandan Road, Phase I and Phase II, with a total consideration of PHP 5,169,932.10.
• Phase I was 100% completed and accepted by the petitioners; Coquial was to be paid PHP 3,174,053.20 according to the auditors' report.
• Petitioners paid only PHP 1,320,000.00, leaving a balance of PHP 1,854,083.20, which they refused to pay.
• Coquial completed 60% of Phase II, costing PHP 1,000,000.00, but the project was not pursued further by the petitioners, who also refused to pay for this portion.
• Coquial sought payment for the owed amounts, including damages and attorney's fees.
• On December 19, 1990, Coquial filed a motion for partial summary judgment for the balance of PHP 1,854,083.20, which the RTC granted on April 24, 1991.
• Petitioners' counsel received the resolution on April 26, 1991, and requested an extension to file a motion for reconsideration, which was granted until May 16, 1991.
• On May 16, 1991, an urgent ex parte motion for an additional ten days was filed by the petitioners and granted; the motion for reconsideration was eventually filed on May 27, 1991.
• The RTC denied the motion for reconsideration on July 15, 1991, and petitioners received the order on August 5, 1991.
• Coquial filed for execution of the partial summary judgment on July 26, 1991, while petitioners filed a notice of appeal on August 28, 1991.
• The RTC denied due course to the notice of appeal on September 3, 1991, and granted the motion for execution; a writ of execution was issued on September 10, 1991, leading to the garnishment of petitioners' bank account on September 30, 1991.
• Petitioners filed for certiorari and mandamus before the CA to nullify the RTC's order and writ of execution and compel the RTC to give due course to their appeal.
• The CA denied the petition on December 6, 1991, stating that the motion for extension of time to file a motion for reconsideration did not interrupt the period of appeal, and the partial judgment had become final and executory.
• Petitioners' motion for reconsideration was denied on February 18, 1992.
• Petitioners then filed the present petition for review on certiorari before the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the partial summary judgment rendered by the RTC is interlocutory, not final.
2. The Supreme Court granted the petition, setting aside the decision and resolution of the Cour...(Unlock)

Ratio:

• The Supreme Court emphasized that a partial summary judgment is merely interlocutory and not a final judgment, as established in the case of Guevarra, et al. v. Court of Appeals, et al.
• Section 4 of Rule 34 of the Rules of Court specifies that if judgment ...continue reading