Case Summary (G.R. No. L-24399)
Facts of the Case
In a collection action initiated by the plaintiff in the City Court of Manila, the defendant sought to file a third-party complaint against the third-party defendant. Ultimately, the City Court ruled in favor of the plaintiff, ordering the defendant to pay the sum of ₱1,992.40, plus interest and attorney's fees. Conversely, the court also ruled in favor of the defendant on the third-party complaint, requiring the third-party defendant to reimburse the defendant for any amounts payable to the plaintiff. Upon the conclusion of the proceedings, only the third-party defendant appealed the judgment against him.
Legal Question
The primary legal issue presented for review was whether the plaintiff's judgment against the defendant could be considered final and executory, despite the fact that the third-party defendant had appealed the judgment related to the third-party complaint.
Court's Ruling
The Court of First Instance determined that the judgment against the defendant had become final and executory due to his failure to appeal. The court reiterated the principle that an appeal taken by one party does not adversely affect other parties who did not appeal. Consequently, the decision was ripe for execution, and the lower court's order to remand the case for execution of the judgment against the defendant was affirmed.
Legal Principles Involved
The decision referenced the precedent established in Singh v. Liberty Insurance Corporation, which clarified that an appeal from a municipal court’s decision vacates that decision only for the appealing party. Thus, in the case at hand, the necessity of maintaining the finality of judgments against non-appealing parties was underscored. The court noted that allowing appeals by one party to vacate judgments against others could lead to illogical outcomes.
Third-Party Complaints
The court elaborated on the nature of third-party complaints, as defined in Rule 6, Section 12 of the Rules of Court. A third-party complaint allows a defendant to bring in a third party to share liability or seek indemnity or contributi
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Case Reference
- Citation: 137 Phil. 239
- G.R. No.: L-24399
- Date: March 28, 1969
- Decided By: Justice Teehankee
Parties Involved
- Plaintiff-Appellee: Firestone Tire and Rubber Company of the Philippines
- Defendant and Third-Party Plaintiff-Appellant: Fernando Tempongko
- Third-Party Defendant-Appellee: Antonio Luna
Legal Issue
- The primary legal question revolves around whether the judgment obtained by the plaintiff against the defendant can be deemed final and executory despite the defendant's subsequent judgment for reimbursement against the third-party defendant, who is the only party that appealed.
Factual Background
- A collection action was initiated by Firestone Tire and Rubber Company in the City Court of Manila.
- During the proceedings, Fernando Tempongko was granted permission to file a third-party complaint against Antonio Luna.
- The City Court rendered a judgment:
- In favor of Firestone, ordering Tempongko to pay a total of P1,992.40 plus interest and attorney's fees.
- In favor of Tempongko against Luna, requiring Luna to reimburse any amounts Tempongko owed to Firestone plus additional attorney's fees.
- Only Luna appealed the judgment rendered against him regarding the third-party complaint.
Procedural History
- Upon appeal, Firestone filed a Motion to Remand the case to the City Court for execution of its judgment against Tempongko, asserting that since Tempongko