G.R. No. L-18940 - Shioji vs. Harvey

In cause No. 19471 before the Court of First Instance (CFI) of Manila, S. Shioji, the petitioner, was successful against the defendants, Toyo Risen Kaisha and Pacific Mail Steamship Co., obtaining a judgment for P19,533.49 plus legal interest and costs.
The defendants, dissatisfied with the decision, appealed by way of a bill of exceptions to the Supreme Court, and the case was docketed as R.G. No. 18592.

The bill of exceptions was filed in the clerk’s office of the Supreme Court on February 16, 1922, with copies served to counsel on February 17, 1922.
Pursuant to Rule 21 of the Supreme Court, appellants were granted a thirty-day period from receipt of the printed bill of exceptions to serve and file their brief; this period expired on March 19, 1922, without any submission or request for extension.
Despite filing a motion on March 22 for an additional period, the court denied this motion on March 24, 1922—acting under Rule 24(a)—and dismissed the appeal for untimely compliance.

After the dismissal, the record was transmitted back to the Court of First Instance on April 12, 1922, and execution was issued to enforce the judgment.
Prior to the levy, respondents (the defendants) filed an action in the CFI, docket No. 21905, alleging that the Supreme Court’s judgment was unconscionable and rendered without due process, and specifically challenged the constitutional validity of Rule 24(a).
Judge Concepcion and later Judge Harvey were involved, with Judge Harvey issuing a preliminary injunction aimed at halting any execution of the Supreme Court's judgment.
This injunction became the subject of a counter-move by respondents, who filed a complaint in prohibition in the Supreme Court to stop Judge Harvey from interfering with the enforcement of the appellate court’s judgment.

Petitioner S. Shioji contended that the lower court had no jurisdiction to review or modify the appellate decision, emphasizing that such interference by Judge Harvey was unlawful.
Respondents challenged the validity of Rule 24(a) as applied in dismissing the appeal, raising questions about its constitutionality and compatibility with statutory rights.
The oral arguments by counsel for both parties were marked by their ability, with particular attention paid to the issue of judicial interference and the enforcement of the Supreme Court’s rules.

Whether a lower court (in this instance, the Court of First Instance) may assume jurisdiction to interpret, review, or reverse a judgment rendered by the Supreme Court, thereby interfering with its execution.
Whether Rule 24(a) of the Supreme Court, which allows dismissal of an appeal for failure to timely file briefs, is valid, constitutional, or in conflict with any law of the United States or the Philippine Islands.