Case Summary (G.R. No. 110147)
Facts of the Case
The case details begin with Metrobank initiating a lawsuit for a sum of money against the respondents on November 25, 1982. Due to non-filing of an answer by the respondents, they were declared in default. On May 26, 1983, the trial court ruled in favor of Metrobank, ordering the respondents to pay the unpaid loan balance, interest, penalties, attorney’s fees, and costs. After the judgment became final, Metrobank sought execution, leading to the sale of shares owned by respondent Roxas Chua at a public auction on July 17, 1991. Roxas Chua later contested the delivery of the certificate of ownership to Metrobank, claiming the shares were conjugal property. However, the trial court denied his motion, leading to further appeals and motions.
Court of Appeals Ruling
The Court of Appeals ruled that a defendant in default can appeal a judgment without needing to have the default lifted, thereby confirming Roxas Chua's right to appeal. The appellate court emphasized that the grounds raised by Metrobank against the validity of Roxas Chua’s appeal were not pertinent to a petition for certiorari, primarily because they did not demonstrate grave abuse of discretion or usurpation of jurisdiction. The appellate court affirmed the trial court’s decision to deny Metrobank’s motion to expunge Roxas Chua’s notice of appeal.
Issues Presented by the Petitioner
Metrobank's petition raised four main issues regarding the propriety of Roxas Chua’s appeal, arguing that the Court of Appeals erred in its interpretation of the rules and the nature of the orders involved. Metrobank contended that Roxas Chua lost standing due to being declared in default, and that the February 18, 1992 order denying the motion to set aside the auction sale was interlocutory rather than appealable. The case primarily focused on whether an appeal from the denial of a motion to hold in abeyance the delivery of a certificate of sale can proceed despite the default status of the respondent.
Court's Ruling on the Issues
The Supreme Court dismissed the petition, siding with the appellate court's position that Roxas Chua retained the right to appeal from the trial court's final orders. The Court clarified that the distinction between interlocutory and final or
...continue readingCase Syllabus (G.R. No. 110147)
Case Overview
- This case involves a petition for review filed by Metropolitan Bank & Trust Company (Metrobank) challenging the Decision of the Court of Appeals (CA) dated December 22, 1992, which dismissed Metrobank's petition for certiorari.
- The CA upheld the Regional Trial Court (RTC) Orders that denied Metrobank's motion to strike the Notice of Appeal filed by Alfonso Roxas Chua Jr., the private respondent.
Facts of the Case
- Metrobank initiated a sum of money action against Pacific Multi Commercial Corporation and Alfonso Roxas Chua Jr. on November 25, 1982, due to the respondents' failure to answer, leading to their being declared in default.
- On May 26, 1983, the RTC rendered a judgment ordering the private respondents to pay various amounts, including an unpaid loan balance, interest, penalty charges, attorney's fees, and costs of suit.
- After the judgment became final, Metrobank sought execution, leading to the garnishment of shares owned by Roxas Chua Jr. in Club Filipino.
- The shares were sold at a public auction on July 17, 1991, with Metrobank as the highest bidder, receiving a Certificate of Sale.
- On August 12, 1991, Roxas Chua Jr. filed a motion to halt