Case Summary (G.R. No. 246017)
Case Background
The dispute arose from a complaint filed by William Samara against Citytrust Banking Corporation and Marine Midland Bank, NA for the recovery of $40,000 in connection with a demand draft purchased by Samara for a joint venture. The trial court found both banks jointly and severally liable to Samara, awarding damages and ordering Marine Midland to reimburse Citytrust for any amount that the latter might pay Samara.
Proceedings in the Lower Court
Following the trial court's decision on March 4, 1986, Marine Midland filed a motion for reconsideration, asserting that the true party liable was Tony Mancuso, not the banks, as Samara had realized Mancuso would not fulfill his obligations. As the appeal period elapsed without Citytrust filing an appeal, Samara filed a motion for execution on April 29, 1986, which led to Citytrust's struggle between the need to appeal and the motion for execution. Ultimately, the trial court set aside the execution order if justice required it, allowing Citytrust's appeal to proceed.
Court of Appeals Decision
Citytrust's filing for appeal was denied by the Fourth Division of the Court of Appeals, which held that the appeal was untimely by 51 days. Hence, Samara's motion for execution was granted. The appellate court ruled that Marine Midland's appeal did not extend to Citytrust, and effectively dismissed Citytrust's subsequent motion for reconsideration.
Arguments of the Petitioner
Citytrust contended that the appeal by Marine Midland operated to benefit it as well since the liability between the banks was interwoven. It cited jurisprudence from previous cases, arguing that interrelated rights mean the outcome for one party should benefit the others. Citytrust also argued against the execution of the judgment during the pendency of the appeal by Marine Midland, fearing unjust repercussions.
Supreme Court Ruling
The Supreme Court affirmed the appellate court's decision, emphasizing that Citytrust's appeal failure did not diminish the finality of the trial court's ruling against it. The Court held that merely sharing liability with Marine Midland did not sufficiently interlink their appeals, as they were defended separately. Moreover, Citytrust's lack of reasons for the late appeal indicated a failure to meet the grounds for late appeals, such as fraud or excusable negligence, further weakening its position.
Execution of Judgment
Reinforcing that final judgments must be enforced without delay when no appeal has been pro
...continue readingCase Syllabus (G.R. No. 246017)
Case Citation
- 253 Phil. 743
- G.R. No. 82009
- Date of Decision: April 10, 1989
- Court: Supreme Court of the Philippines
Parties Involved
- Petitioner: Citytrust Banking Corporation
- Respondents: The Honorable Fourth Division, Court of Appeals; William Samara (Private Respondent)
Background of the Case
- On October 3, 1983, William Samara filed Civil Case No. 50248 against Citytrust Banking Corporation and Marine Midland Bank, NA in the Regional Trial Court (Branch 160) of Pasig, Metro Manila.
- The complaint involved a US$40,000 demand draft purchased by Samara from Citytrust for a joint venture with Tony Mancuso, intended for the transportation of entertainers.
- Samara executed a stop-payment order on December 23, 1980 after concerns arose regarding Mancuso's reliability.
- Citytrust initially honored the stop-payment, re-crediting Samara's account, but later debited the account after Marine Midland processed the draft.
- Samara's efforts to recover funds from Mancuso were unsuccessful, leading to his suit against the banks.
Proceedings in the Regional Trial Court
- On March 4, 1986, the Regional Trial Court ruled in favor of Samara, holding both Citytrust and Marine Midland jointly and severally liable for damages.
- The