G.R. No. L-35919 - Republic vs. Presiding Judge, Branch XV, Court of 1st Instance of Rizal

In April 1970, respondent Jose Sison filed a complaint in Civil Case No. 437-M against the Rice and Corn Administration (RCA) for a monetary sum.
The complaint was predicated on Sison’s interest as an assignee of the purchase price for unpaid deliveries of corn grains made by the RCA.

The RCA moved to dismiss the complaint on the ground that, as a mere governmental agency of the Republic of the Philippines, it was not suable.
On May 5, 1970, respondent Sison filed a motion to amend his complaint to better demonstrate his actionable interest in relation to the unpaid deliveries.
A subsequent motion to dismiss the amended complaint, relying on similar grounds of non-suability, was filed by the RCA on June 1, 1970.
The respondent Judge denied this dismissal in an order dated June 30, 1970.

The RCA filed its answer on September 22, 1970.
After trial, on May 10, 1972, the respondent Judge issued a decision favoring Sison.

The RCA was ordered to pay Sison the sum of One Million Six Hundred Twenty-Eight Thousand Four Hundred Fifty-One Pesos and Fifty-Four Centavos (P1,628,451.54) with legal interest accruing from 1965 until full payment.
Additionally, the RCA was ordered to pay attorney’s fees amounting to Two Hundred Fifty Thousand Pesos (P250,000.00) along with the costs of the suit.

On May 24, 1972, the RCA filed a notice of appeal together with a motion requesting a thirty-day extension (from June 16, 1972) for filing the record on appeal; the motion was granted on May 27, 1972.
The RCA submitted its record on appeal on June 15, 1972, before the lapse of the original deadline.
Respondent Sison, on June 22, 1972, filed a motion to dismiss the RCA’s appeal on the basis that the RCA failed to post the required appeal bond.
On June 26, 1972, the respondent Judge issued an order approving the record on appeal while denying the RCA’s exemption from paying legal fees and from the posting of an appeal bond on the ground that the RCA was a mere instrumentality of the Republic of the Philippines.
On July 1, 1972, the same Judge issued another order giving the RCA five (5) days to post an appeal bond.
After the petitioner (representing the RCA) filed a motion for reconsideration on July 11, 1972, alleging the RCA’s exemption from posting an appeal bond, the Judge ultimately issued an order on July 22, 1972, which:

Held that the RCA, as a mere governmental instrumentality, was not exempt from paying legal fees and posting an appeal bond.
Dismissed the RCA’s appeal for its failure to file the required appeal bond.

A motion for a writ of execution and approval of the bill of costs filed by respondent on August 22, 1972, which was opposed by the petitioner on September 1, 1972.
An order dated September 28, 1972, by the respondent Judge for the issuance of a writ of execution against goods and chattels of the RCA.
Filing of an urgent motion to quash the writ of execution by the petitioner on October 30, 1972, which remained unresolved.

Consequently, the petitioner (RCA) elevated the matter by filing the present petition for certiorari and mandamus with a preliminary injunction seeking to set aside the orders dated June 26, July 1, and July 22, 1972.

The single, central issue raised in the petition was whether the RCA is exempt from paying legal fees and from the requirement to post an appeal bond, given its status as a governmental agency.

Whether the Rice and Corn Administration (RCA) is to be considered a governmental agency without a separate, distinct, and independent legal personality from the Republic of the Philippines.
Whether, due to its characterization as a governmental instrumentality tasked with executing government policies, the RCA is exempt from the obligation to pay legal fees and post an appeal bond when appealing an adverse judgment.
Whether the dismissal of RCA’s appeal for not posting the required appeal bond was correct under the applicable law governing governmental agencies and their immunities.