Title
Delta Motors Corp. vs. Court of Appeals
Case
G.R. No. 121075
Decision Date
Jul 24, 1997
Delta Motors challenged improper service of summons and execution of a default judgment; Supreme Court upheld appellate rulings, denying Delta's motion and affirming procedural limits.

Case Summary (G.R. No. 141386)

Applicable Law and Constitutional Framework

The proceedings and the Court’s decision are governed by the 1987 Constitution as the controlling charter (decision rendered after 1990), by the Revised Rules of Court (notably Rule 65, and Rule 51, Section 7 regarding appellate procedure in the Court of Appeals), and established jurisprudence cited by the courts below.

RTC Judgment and Attempts at Service

DELTA was declared in default in Civil Case No. 84-23019. On December 5, 1984, the RTC rendered judgment ordering DELTA to pay P20,061,898.97 plus attorney’s fees (25% of total obligation) and costs. The judgment could not be personally served on DELTA because the corporation had earlier been dissolved; PNB had assumed DELTA’s operations. SIHI moved for and obtained an order permitting service of the judgment by publication (order of December 6, 1986); the judgment was published in a Manila weekly named the Thunderer. SIHI then moved for execution; the RTC issued a writ of execution on March 11, 1987, under which various DELTA properties were levied and sold.

First Court of Appeals Proceeding (CA-G.R. SP No. 23068) and Effect on Finality

DELTA initially filed a certiorari petition with the Court of Appeals (CA-G.R. SP No. 23068) asserting lack of valid service of summons and that the RTC decision was null and not final. By decision dated January 22, 1991, the Court of Appeals ruled that the RTC decision was validly rendered but that the record lacked proof that a copy of the judgment had been properly served on PNB (which had assumed DELTA’s operations). The CA concluded that, because service on the corporation’s successor was not shown, the judgment had not attained finality; service by publication did not cure that defect. The CA therefore held that DELTA could still be served and might appeal within the reglementary period once proper service occurred. Motions for reconsideration were denied.

Subsequent Procedural Steps, Dismissal of DELTA’s Notice of Appeal, and CA-G.R. SP No. 29147

After administrative and appellate maneuvers (including a denied petition for review at the Supreme Court for noncompliance with a procedural circular), DELTA filed a Notice of Appeal with the RTC on November 12, 1991, stating it was appealing from the December 5, 1984 decision. SIHI moved to dismiss that Notice of Appeal on the ground that DELTA had obtained a certified true copy of the RTC decision on September 21, 1990 and thus the 15-day appeal period had expired. The RTC dismissed DELTA’s Notice of Appeal; DENIALs of motions for reconsideration by the RTC followed. DELTA filed certiorari with the Court of Appeals (CA-G.R. SP No. 29147) seeking annulment of the RTC orders dismissing the Notice of Appeal and elevation of the records to the Court of Appeals.

Court of Appeals Decision in CA-G.R. SP No. 29147 and Related Appeals

The Court of Appeals issued a restraining order in October 1992, gave due course to DELTA’s petition, and after full briefing promulgated judgment on June 17, 1993 setting aside the RTC orders (dismissing the Notice of Appeal and denying reconsideration) and ordering the RTC to elevate the records to the Court of Appeals. The RTC complied and elevated the records. SIHI appealed that CA decision to the Supreme Court (G.R. No. 110677), contending DELTA had lost the right to appeal because of lapse of the 15-day period from receipt of the certified copy. While SIHI’s petition was pending before this Court, DELTA filed an Omnibus Motion in CA-G.R. SP No. 29147.

The Omnibus Motion: Relief Sought and Initial CA Treatment

On February 14, 1994 DELTA filed an Omnibus Motion in CA-G.R. SP No. 29147 seeking, among other things, (1) declaration null and void ab initio of the RTC order of March 11, 1987 issuing the writ of execution, (2) declaration null and void of the writ of execution issued pursuant thereto, and (3) annulment of sheriff’s proceedings implementing the writ. SIHI opposed the Omnibus Motion arguing that (a) the CA lacked jurisdiction to act because of a pending petition for review with the Supreme Court, (b) the Omnibus Motion was barred by res judicata, and (c) the filing constituted forum-shopping. The CA, noting a pending Supreme Court petition involving the same parties, initially declined to act on the Omnibus Motion.

Court of Appeals Resolutions of January 5, 1995 and July 14, 1995; Motions for Reconsideration and Clarification

After the Supreme Court denied SIHI’s petition and motion for reconsideration, DELTA renewed its request that the CA resolve the Omnibus Motion. On January 5, 1995 the Court of Appeals denied DELTA’s Omnibus Motion on the ground that the matters sought were not issues raised by petitioner in CA-G.R. SP No. 29147 and therefore were not within the CA’s jurisdiction in that petition. DELTA moved for reconsideration, arguing (inter alia) that the Omnibus Motion relief fell within the general prayer of the petition and that it could not file the motion in the RTC because the records had already been elevated. SIHI filed a motion for clarification seeking deletion of a paragraph in the CA’s January 5, 1995 Resolution that characterized certain trial-court proceedings as null and void. On July 14, 1995 the CA granted SIHI’s motion for clarification (deleting the paragraph) and denied DELTA’s motion for reconsideration, holding that the only issues in CA-G.R. SP No. 29147 were the validity of the RTC orders dated June 3, 1992 and September 14, 1992, and that matters in DELTA’s Omnibus Motion were not within the scope of that petition.

Issues Presented to the Supreme Court and Standard of Review

DELTA’s certiorari petition to the Supreme Court challenged the CA’s two Resolutions (January 5 and July 14, 1995), principally contending that (1) the Omnibus Motion raised matters incidental to and included in the CA’s appellate jurisdiction and therefore the CA had jurisdiction to decide them, and (2) the CA erred in deleting the paragraph challenged by SIHI because that paragraph contained factual findings and therefore was not mere obiter dictum. The Supreme Court reviewed whether the CA committed reversible error in declining to adjudicate matters not pleaded and in striking the paragraph as obiter dictum.

Supreme Court Reasoning and Disposition

The Supreme Court found no reversible error. It reasoned that the June 17, 1993 CA decision in CA-G.R. SP No. 29147 had become final as to DELTA and that the only issues properly raised and argued in that petition were the validity of the RTC orders of June 3, 1992 and September 14, 1992. The Omnibus Motion sought relief concerning orde

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