Case Summary (G.R. No. 103590)
Facts
- GSIS loaned QRSI funds for the development of 4,493 housing units in Molino, Bacoor, Cavite.
- QRSI contracted with Valencia for construction phases and failed to pay upon completion.
- Valencia sued QRSI and GSIS in Civil Case No. BCV-78-33, prayed for preliminary attachment, and proved his claim at trial.
- On March 2, 1982, the RTC rendered judgment ordering QRSI to pay Valencia specified sums with legal interest and directing GSIS to hold retained funds as payment on QRSI’s obligation, without personal liability beyond those retentions.
Procedural History
– Valencia moved for execution pending appeal but no appeal or reconsideration was filed by QRSI or GSIS.
– Writs of execution returned unsatisfied; Valencia filed for examination of GSIS debtors and contempt proceedings against GSIS officials.
– GSIS partially paid ₱154,476.14 on November 26, 1982, pending resolution of its motion for reconsideration.
– Multiple alias writs and garnishment notices were issued (1983–1986); GSIS contended it owed QRSI funds, not vice versa.
– RTC in July 1985 and May 1986 ordered GSIS to pay retained funds to Valencia and a co-claimant, denying GSIS’s claims of set-off.
– GSIS appealed by certiorari to the CA (CA-G.R. SP No. 09956); CA dismissed GSIS’s petition, holding the March 1982 decision final and GSIS’s compensation defense waived by partial payment.
– SC denied GSIS’s Rule 45 petition (G.R. No. 87980) in November 1989 and January 1990 resolutions.
– Valencia moved for another writ of execution; RTC on June 7 and September 10, 1990 set interest rates at 12–21% p.a. per Central Bank circulars and imposed attorney’s fees.
– GSIS petitioned the CA again (CA-G.R. SP No. 24021) via certiorari under Rule 65, challenging the tenor of the execution orders.
Issues
- Whether the CA’s resolution of January 15, 1992 improperly applied res judicata and estoppel to bar GSIS’s petition.
- Whether the RTC orders of June 7 and September 10, 1990 varied the tenor of the original judgment by imposing higher interest rates and attorney’s fees beyond the scope of its March 2, 1982 disposition.
- Whether the legal rate of interest on the March 1982 judgment is six percent (6%) per annum under Article 2209 of the Civil Code and not the ceilings prescribed by Central Bank Circulars.
- Whether GSIS’s partial payment estops it from contesting interest rates or its liability beyond retention funds.
Ruling of the Supreme Court
- Res judicata and estoppel do not apply. Prior CA Decision (CA-G.R. SP No. 09956) and SC Resolution (G.R. No. 87980) did not address the interest-rate issue or the variation of the judgment’s tenor; they only confirmed finality, the availability of GSIS funds, and waiver of set-off. Identity of issues is lacking.
- The June 7/September 10, 1990 orders varied the dispositive tenor of the March 2, 1982 decision by:
a. Imposing interest and attorney’s fees not directed in the original judgment.
b. Extending GSIS’s liability beyond the “retained and obtained” funds for QRSI, contrary to the proviso that GSIS “shall not be personally liable…except as herein above-ordered.”
c. Neglecting to inquire into the exact amount of retentions GSIS held before enforcing beyond that limit. - The legal interest rate on the sums adjudged against QRSI is six percent (6%) per annum under Article 2209, Civil Code. Central Ba
Case Syllabus (G.R. No. 103590)
Procedural Background
- Petition for review on certiorari under Rule 45 (G.R. No. 103590) filed by GSIS to annul the Court of Appeals’ Resolution of January 15, 1992 in CA-G.R. SP No. 24021.
- The challenged Resolution reversed the Court of Appeals’ own Decision of June 28, 1991, which had set aside the Regional Trial Court’s orders of June 7, September 10, and December 5, 1990.
- These RTC orders had directed GSIS to pay large sums to private respondent Valencia in execution of the RTC’s March 2, 1982 decision in Civil Case No. BCV-78-33.
Facts of the Case
- Queen’s Row Subdivision, Inc. (QRSI) entered into a project agreement with GSIS for financing the development of 4,493 housing units at Molino, Bacoor, Cavite, to be sold to GSIS members.
- QRSI subcontracted phases of land development to Victor G. Valencia, who completed his work and demanded payment.
- QRSI refused to pay; Valencia sued QRSI and GSIS for sums due and sought a writ of preliminary attachment.
RTC Decision of March 2, 1982
- Judgment in favor of Valencia against QRSI:
• P448,374.01, P204,821.32, P102,866.37 for three causes of action, and return of P10,000 performance bond, with legal interest from respective demand dates.
• Attorney’s fees equal to 20% of amounts recovered.
• GSIS required to hold and deliver to Valencia whatever funds it had “granted to, retained and obtained for” QRSI, to be credited against QRSI’s obligation.
• GSIS expressly “not personally liable” beyond those held funds; contractor’s lien to be respected pending payment.
Post-Judgment Proceedings
- Valencia’s motion for execution pending appeal granted; writs returned unsatisfied.
- Examination of GSIS official ordered; GSIS partially paid P154,476.14 in November 1982.
- Alias writ issued October 20, 1983; garnishment notice on GSIS-held QRSI funds.
- GSIS denied holding QRSI funds; claimed it was QRSI’s creditor (P58,261,773.19).
- RTC Order of July 5, 1985: GSIS ordered to pay judgment from held funds less prior payments.
- GSIS motions for reconsideration denied May 22 and July 10, 1986; alias writ of June 9, 1986 issued; garnishments served.