G.R. No. 89431 - Valencia vs. Court of Appeals

On July 6, 1984, petitioner Eriberto G. Valencia filed Civil Case No. 7554-M before the Regional Trial Court, Branch XL at Malolos, Bulacan.
The action sought the rescission of a lease contract covering a 24‑hectare fishpond in Paombong, Bulacan, with an accompanying prayer for a writ of preliminary mandatory injunction against the private respondents.

Private respondents filed an answer which included a counterclaim for damages.
During the pendency of the case, the trial court found that the lease contract had expired, and the defendants had peacefully surrendered the fishpond.
In its decision dated November 29, 1988, the trial court declared the petition for rescission moot and academic, limiting the dispute solely to the matter of damages.
The decision awarded each defendant P100,000.00 as moral damages and P50,000.00 as exemplary damages, while also ordering petitioner to pay P30,000.00 as attorney’s fees in addition to court costs.

Petitioner received a copy of the decision on January 10, 1989, after defendant Bagtas acknowledged receipt on January 3, 1989.
On January 16, 1989, petitioner filed a notice of appeal. Subsequently, on the same day, the respondent judge issued an order directing that the case records be forwarded to the Court of Appeals.
On January 17, 1989, private respondents filed a motion for execution pending appeal, invoking Section 2 of Rule 39 of the Rules of Court and citing precedents that supported the filing of a bond as a sufficient ground for execution.
Respondents posted a bond amounting to P330,000.00 via the Domestic Insurance Company of the Philippines.
On March 6, 1989, despite petitioner’s opposition, the respondent judge granted the motion for execution pending appeal and set a deadline (up to April 27, 1989) for petitioner to contest this by filing a counter bond.
Petitioner’s motion for reconsideration was denied on April 6, 1989, with the trial court affirming that an offer of a bond constituted a good ground for execution pending appeal.
On April 10, 1989, a writ of execution pending appeal was issued by the trial court.

Petitioner then elevated the matter by filing a petition for certiorari, prohibition, and mandamus with the Court of Appeals.
The petition challenged, among other issues, the trial court’s issuance of a writ of execution pending appeal, arguing that:

The execution was ordered after the appeal was ostensibly perfected, given that defendants had received the decision earlier.
The trial court had lost jurisdiction upon perfection of the appeal, making the execution order invalid.
Merely posting a bond did not constitute a “good reason” for granting execution pending appeal, especially for consequential, exemplary, and moral damages.

The Court of Appeals dismissed the petition for certiorari on June 20, 1989, and also denied petitioner's motion for reconsideration dated August 9, 1989.
The Supreme Court, after issuing a temporary restraining order on August 28, 1989, ultimately granted the petition by reversing and setting aside the resolutions of the Court of Appeals, and annulled the writ of execution pending appeal.

Whether the trial court erred in granting an execution order pending appeal solely on the basis of the posting of a bond by the respondents.
Whether the mere filing of a notice of appeal is sufficient to perfect the appeal, thus affecting the propriety of executing the judgment before the appeal’s final perfection.

Whether the trial court lost jurisdiction to entertain the motion for execution pending appeal after the appeal was deemed perfected upon the expiration of the last day for filing an appeal.
Whether the respondent judge’s act of “giving due course” to the notice of appeal affected the timing or perfection of the appeal.

Whether awards for moral and exemplary damages may be executed pending appeal, given the inherent uncertainty and final determination of such damages in the appellate process.

Whether the filing of a supersedeas bond constitutes a plain, speedy, and adequate remedy to prevent the execution of the judgment pending appeal, or whether certiorari is an appropriate remedial measure in such circumstances.