G.R. No. 205810 - Estate of Bueno vs. Estate of Peralta

On April 27, 1990, private respondent Rogelio R. Coquial filed a complaint before the Regional Trial Court (RTC) of Quezon City (Civil Case No. Q-90-5337) against petitioners Province of Pangasinan and Provincial Governor Rafael M. Colet.
The complaint alleged the existence of a contract for the improvement of 6.492 kilometers of the Urdaneta-Mapandan Road (comprising Phase I and Phase II) for a total consideration of P5,169,932.10.
Specific allegations included:

Completion and acceptance of Phase I, warranting a payment of P3,174,083.20 according to the auditors’ report.
Petitioners’ alleged partial payment of only P1,320,000.00, leaving an unpaid balance of P1,854,083.20 for Phase I.
Completion of 60% of Phase II, costing P1,000,000.00, which petitioners later refused to fund as they decided not to pursue the project.

The relief sought by the private respondent included the unpaid balance of Phase I, additional sums for Phase II work, monetary awards for damages, and attorney’s fees.

On December 19, 1990, the private respondent filed a motion for partial summary judgment targeting the remaining balance of P1,854,083.20 from Phase I.
The RTC granted the motion on April 24, 1991, issuing a resolution that ordered petitioners to pay the outstanding balance of P1,854,083.20.
During the hearing on April 26, 1991, petitioners’ counsel received a copy of the resolution and requested an initial ten-day extension to file a motion for reconsideration.
The trial court granted an extension for twenty days (until May 16, 1991).
On May 16, 1991, petitioners’ counsel filed an urgent ex-parte motion for an additional ten-day extension (extending the deadline to May 26, 1991) for the filing of the motion for reconsideration, which was granted by the RTC.

On May 27, 1991, petitioners filed the motion for reconsideration, arguing that since May 26, 1991, fell on a Sunday, their filing on the following day remained timely.
The RTC denied the motion on July 15, 1991, with the petitioners receiving a copy of the denial on August 5, 1991.
On July 26, 1991, the private respondent filed a motion for execution of the partial summary judgment.
Petitioners subsequently filed a notice of appeal on August 28, 1991.
The RTC, in its order dated September 3, 1991, denied due course to the notice of appeal, reasoning that it should have been filed no later than May 11, 1991, and holding that the RTC resolution dated April 24, 1991, had become final and executory pursuant to Section 5, Rule 36 of the Rules of Court.
Following this, the RTC issued a writ of execution on September 10, 1991, and ordered the garnishment of petitioners’ bank account on September 30, 1991.

Petitioners elevated the matter by filing a petition for certiorari before the Court of Appeals, seeking to nullify the RTC’s order dated September 3, 1991, the writ of execution, and to issue a mandamus compelling the RTC to give due course to the appeal.
On December 6, 1991, the Court of Appeals denied the petition for certiorari, holding that the extension motion for filing a motion for reconsideration was void and that the RTC’s partial summary judgment had become final and executory as of May 16, 1991.
Petitioners then filed an urgent motion for reconsideration on December 19, 1991, contending that the RTC’s resolution was merely interlocutory—citing the case of Guevarra, et al. v. Court of Appeals, and supported by an addendum dated December 11, 1991.
The Court of Appeals denied this motion on February 18, 1992, explaining that the petitioners merely reiterated their earlier arguments without presenting new grounds, and found the respondent’s opposition convincing.
Thereafter, petitioners brought the case before the Supreme Court, invoking the ruling in Guevarra, et al. v. Court of Appeals, asserting that the partial summary judgment should be considered interlocutory and not final.

Whether the RTC’s partial summary judgment is final or merely interlocutory in character.
Whether the intervening filings—specifically, the motion for extension to file a motion for reconsideration—could lawfully interrupt the period for appeal.

Whether the trial court’s and the Court of Appeals’ reliance on Section 5, Rule 36 of the Rules of Court, in declaring the resolution final and executory, was proper.
Whether Section 4 of Rule 34, which explicitly addresses partial summary judgments, should control, given that such judgments do not dispose of the entire case.

Whether the writ of execution and subsequent garnishment orders issued against petitioners were proper in view of the interlocutory nature of the judgment.
Whether execution of the partial summary judgment is permissible when the issue is not fully adjudicated.