Case Digest (G.R. No. 141241)
Facts:
Republic of the Philippines, Through Its Trustee, The Asset Privatization Trust v. "G" Holdings, Inc., G.R. No. 141241, November 22, 2005, the Supreme Court Third Division, Corona, J., writing for the Court.On May 21, 1992 the Committee on Privatization approved a negotiated sale of 90% of the shares of Maricalum Mining Corporation (MMC); the Asset Privatization Trust (APT) as trustee of the Republic pursued the sale. "G" Holdings, Inc. signified interest and submitted the best bid; after negotiations the parties executed a purchase and sale agreement on October 2, 1992 for P673,161,280, with a downpayment and a balance payable in four tranches over ten years.
A dispute later arose over when installment payments should commence: the Republic claimed payments should begin seven months from signing, while "G" Holdings insisted they should begin seven months after fulfillment of the closing conditions. "G" Holdings filed a complaint for specific performance and damages in the Regional Trial Court (RTC) of Manila, Branch 49, docketed as Civil Case No. 95-76132, to compel closing consistent with the agreement.
At pre-trial the parties agreed the issue was one of law and submitted the case for decision. On June 11, 1996 the RTC ruled for "G" Holdings, ordering the APT to execute a Deed of Transfer and deliver the shares and notes within 30 days after payment in full of the balance computed at present value. On June 28, 1996 the Solicitor General filed a notice of appeal on behalf of the Republic, but erroneously filed it with the Court of Appeals (CA) instead of the trial court.
No further remedies were pursued until July 2, 1999, when the Republic, through the APT, filed a petition for annulment of judgment in the CA (CA-G.R. SP No. 53517), alleging (1) grave abuse of discretion amounting to lack of jurisdiction because the RTC rendered decision before the Republic’s formal offer of evidence and without ruling on admissibility, and (2) extrinsic fraud because the Solicitor General’s misfiling prevented an appeal. The CA, by resolution dated December 21, 1999 (Sixth Division), dismissed the petition, finding no extrinsic fraud, that the RTC had jurisdiction over person and subject matter and had considered documentary evidence (which formed part of the pleadings), and that any irregularity was an appealable error that had become final.
The Republic filed this petition for review on certiora...(Subscriber-Only)
Issues:
- Was the petition properly brought on behalf of the Republic given the absence of proof that the Solicitor General deputized APT lawyers to represent the government?
- Did the RTC commit grave abuse of discretion amounting to lack of jurisdiction when it rendered judgment before the Republic formally offered its evidence and without ruling on admissibility?
- Did the Solicitor General’s filing of the notice of appeal in the wrong forum amount to extrinsic fraud that prevented the Republic from appealing ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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