G.R. No. 133442 - People vs. Almazan

On August 1, 1984, Remington Industrial Sales Corporation filed a complaint for sum of money with damages against Marinduque Mining and Industrial Corporation (MMIC) for unpaid purchases of construction materials amounting to P921,755.95, with an annual interest of 18%.
On September 7, 1984, the complaint was amended to implead additional defendants, including Philippine National Bank (PNB), Development Bank of the Philippines (DBP), Nonoc Mining and Industrial Corporation, Maricalum Mining Corporation, Island Cement Corporation, and later the Asset Privatization Trust, due to issues related to foreclosure sales of MMIC’s properties.

On April 10, 1990, the RTC rendered a decision in favor of Remington, holding all the defendants jointly and severally liable to pay the principal obligation, accrued stipulated interest (as of June 22, 1984) and an additional 10% surcharge per annum by way of penalty until full payment.
The RTC’s dispositive order mandated that several defendants were to pay the sum, attorney’s fees equivalent to 10% of the amount due, and the costs.
All defendants appealed, and on October 6, 1995, the Court of Appeals (CA) affirmed the RTC decision in CA-G.R. SP No. 27720.
PNB and DBP separately appealed these affirmations to the Supreme Court in different cases, ultimately resulting in decisions reversing the CA ruling in their respective cases.

On March 9, 2001, following Remington’s motion for execution, the RTC issued a writ of execution against Maricalum.
Maricalum’s bank deposits at Global Bank (P920,755.95) and Equitable PCI Bank (P32,256.48) were garnished.
Maricalum later filed a petition for certiorari and prohibition with the CA (CA-G.R. SP No. 65209) contesting the execution, and moved to intervene in the PNB case – which was denied.

The Supreme Court, in its Decision dated February 11, 2008 (Maricalum case), granted Maricalum’s petition and annulled the RTC execution orders.
This decision clarified that the executed RTC decision, which had become final and executory (dating from April 10, 1990), was rendered moot by the subsequent dismissal of the complaint in the DBP and PNB cases.
Maricalum subsequently filed a motion for restitution and a supplemental motion before the RTC concerning the garnished funds.

On April 26, 2010, the CA reversed and set aside the RTC orders, directing Remington to return and restitute the garnished amounts of P920,755.95 and P32,256.48, with interest computed at 12% per annum until fully satisfied.
Remington filed a motion for reconsideration, which was denied by the CA on September 30, 2010.
Remington’s petition further contested the CA’s annulment of the RTC orders, the order of restitution, and the imposition of 12% interest per annum.

The Supreme Court, in its Decision rendered on June 22, 2015, denied Remington’s petition.
The Court affirmed the CA’s ruling with a modification of the interest rate – applying 12% per annum only until June 30, 2013, and from that date onward applying 6% per annum in conformity with the BSP-MB Circular and recent jurisprudence.
The Court emphasized the effect of the Supreme Court’s previous rulings in DBP, PNB, and Maricalum, noting that the RTC decision’s execution against Maricalum had lost its legal basis due to the supervening event of dismissal and the resulting alteration of rights.

Whether the annulment and setting aside of the RTC orders (dated December 19, 2008 and July 30, 2009) was proper in view of the established finality and executory nature of the RTC decision dated April 10, 1990.

Did the reversal, based on the supervening event arising from the Supreme Court decisions (DBP and PNB cases), warrant the disrupting of the execution of a final judgment?

Whether it is proper to order the return and restitution of garnished amounts to Maricalum, considering the principle of immutability of final judgments.

Can the product of a final and executory judgment be disturbed, when subsequent events (dismissals) have occurred affecting the rights of the parties?

Whether the imposition of interest at 12% per annum on the garnished amounts is legally sound.

Should the interest rate remain at 12% per annum throughout, or must it be modified in view of the BSP-MB Circular No. 799, which sets the legal rate at 6% per annum for obligations after a certain period?

What is the role of the supervening event (i.e., the dismissal of Civil Case No. 84-25858 in the DBP and PNB decisions) in invalidating the RTC’s execution orders?