G.R. No. 125539 - People vs. Patalin Jr.

The Supreme Court in G.R. No. 63855 ruled that the deceased spouses, Jose and Salvacion Tayengco, were the lawful owners of the properties under receivership.
In G.R. No. 60076, the Court affirmed the appointment of Traders Royal Bank (TRB) as receiver pendente lite, thereby establishing the legitimacy of TRB’s appointment and its subsequent actions.

With the closure of the receivership proceeding following the aforementioned rulings, TRB rendered its final accounting of the funds it had held under receivership.
TRB deducted P219,016.24 as its receiver’s fee from the receivership funds instead of turning over the full amount to the Tayengcos.

The Regional Trial Court of Iloilo, Branch 5, approved, on July 5, 1988, the final accounting submitted by TRB, which included the deduction of its fee from the funds under receivership.
This approval was based on the notion that the compensation of the receiver was part of settling the accounts upon the termination of the receivership.

The Tayengcos challenged the trial court’s order before the Court of Appeals, contending that TRB’s fee should be charged against the losing party rather than being deducted from the receivership funds.
In its decision on February 12, 1993, the Court of Appeals ruled that TRB could not deduct its fee from the funds under its receivership and ordered TRB to return the P219,016.24 to the Tayengcos, placing the responsibility for the fee solely on the losing parties (Cu Bie, et al.).
TRB subsequently filed a motion for reconsideration, which was denied on August 17, 1993.

TRB argued that the Court of Appeals erred by reversing the Supreme Court decision in G.R. No. 60076 regarding the settlement of the receiver’s account and by ordering the fee’s return to the heirs of Jose Tayengco.
TRB contended that the Court of Appeals lacked jurisdiction in CA-G.R. No. 21423 and that its decision violated the “Bar by Final Judgment” rule.
Furthermore, TRB raised doubts on whether the CA decision was barred by res judicata in light of the prior ruling in G.R. No. 60076.

Is the Court of Appeals’ decision dated February 12, 1993, barred by res judicata on the basis of the prior ruling in G.R. No. 60076 regarding TRB’s appointment as receiver?
Does the difference in the underlying causes of action between G.R. No. 60076 and CA-G.R. No. 21423 preclude the application of res judicata?

Should TRB’s receiver’s fee be deducted solely from the funds under receivership?
Or, must the compensation be charged against the losing party (or equally apportioned among litigants) as mandated by the Rules of Court?