Title
Iloilo Trading Center and Exchange vs. Rodas
Case
G.R. No. 48468
Decision Date
Oct 24, 1941
A 1941 case where the Supreme Court upheld execution pending appeal, ruling the trial judge validly deemed the appeal dilatory, affirming discretion to order execution without requiring proof of insolvency.

Case Summary (G.R. No. 203697)

Relevant Facts

The central issue revolves around an order made by Judge Sotero Rodas, which granted the motion for the issuance of a writ of execution against Iloilo Trading Center and Exchange, contingent upon the posting of a supersedeas bond. This bond was required to be of sufficient value to cover the judgment amount of ₱1,677.22, which included interest and costs. The original judgment was rendered on March 31, 1941, against Iloilo Trading Center.

Legal Arguments

Iloilo Trading Center asserts that the trial judge acted with grave abuse of discretion by concluding that their appeal was taken merely for purposes of delay. The petitioner contends that such a declaration does not constitute a valid basis for the issuance of execution pending appeal, emphasizing that they have not exhibited any financial distress that would indicate an intent to defraud creditors. They argue their financial viability, characterized by a capitalization of around ₱50,000, should suffice to support their claim.

Court's Reasoning

The Supreme Court referred to a similar precedent in Jacinto Presbitero et al. vs. Judge Sotero Rodas, underscoring that Rule 39, Section 2 empowers the court to order execution of a judgment during the pendency of an appeal when justified. The Court reaffirmed that a judge's concerns about potential dilatory tactics are a sound basis for allowing execution to proceed, as these tactics undermine the integrity of the judicial process.

Conclusion

The Supreme Court noted that the arguments prese

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