G.R. No. 113886 - Spouses Chua vs. Court of Appeals

The case involves an ejectment suit concerning four lots located on Galicano St., Batangas City.
The Municipal Trial Court (MTC), Branch II, rendered a judgment on March 5, 1993, in favor of petitioners (Spouses Marciano Chua and Chua Cho), ordering the ejectment of private respondents (Spouses Mariano C. Moreno and Sheila Moreno) and the payment of monthly rentals of ₱50,000.00 starting from April 7, 1992, until possession was surrendered. Additionally, the judgment mandated the payment of ₱20,000.00 as attorney’s fees.

The decision was received by private respondents’ counsel on March 10, 1993, after which a notice of appeal was filed on March 11, 1993.
On March 16, 1993, the MTC transmitted the case records to the Regional Trial Court (RTC).
Petitioners moved for the execution of the decision on March 29, 1993, despite the pending appeal.

On June 10, 1993, the RTC, considering the timely transmission of the records, denied the motion for immediate execution and ordered petitioners to file a supersedeas bond within five days.

The bond was fixed at ₱550,000.00.
Petitioners were also directed to deposit ₱150,000.00 for accrued rentals (for April, May, and June 1993) and to make periodic monthly deposits of ₱50,000.00 starting July 1993.

On June 17, 1993, the RTC issued another order granting petitioners an additional five-day extension to file the supersedeas bond.
Petitioners initially admitted to posting a cash bond of ₱550,000.00, which was later, on September 20, 1993, substituted by a surety bond upon motion.

Petitioners challenged the RTC’s extension orders and questioned whether the bond should have been filed with the MTC or the RTC, alleging confusion due to the MTC transmitting records before the appeal period had expired.
They further argued that fixing the bond’s amount without reference to the underlying rents violated equal protection principles and that such discrepancies made immediate execution inequitable.
However, these contentions were countered by the opposing party’s submission that the procedural requirements were clear and unambiguous under the Rules of Court.

The RTC erred by extending the period for filing the supersedeas bond beyond the period for perfecting the appeal.
The mandatory nature of Section 8 of Rule 70 did not allow any discretion, and thus the failure to timely file the bond warranted the immediate execution of the judgment.

The CA set aside the RTC’s June 10 and June 17 orders while sustaining the substitution order approved on September 20, 1993.
Petitioners also raised issues regarding potential deprivation of property and due process; however, these were addressed separately and found not compelling enough to override the mandatory procedural requirements.

Whether the supersedeas bond was filed within the prescribed period for perfecting the appeal.
Whether the failure to file the bond on time automatically necessitates the issuance of a writ of execution.

Whether the RTC had the discretionary power to extend the period for filing the supersedeas bond beyond the appeal perfection period.
The proper computation and determination of the bond’s amount.

Which court (MTC or RTC) should have fixed and received the supersedeas bond given the transmission of records before the expiration of the appeal period.
Whether the alleged confusion regarding the venue for filing the bond justifies an exception to the mandatory rule.

Whether the issuance of a writ of execution pending appeal, in light of petitioners’ claim of co-ownership and potential deprivation of their business and property, violates due process.
Whether the risk of irreparable injury to petitioners constitutes a compelling reason to delay execution.