Case Summary (G.R. No. 105909)
Background of the Case
On March 17, 1989, the Regional Trial Court of Tanay, Rizal, Branch 80, rendered a judgment in favor of the Municipality against PPC, ordering PPC to pay various amounts accruing from municipal tax and fees due between the years 1975 to 1986. Following the tribunal's decision on June 3, 1991, which affirmed the lower court's ruling with a modification, the judgment became final and executory by July 13, 1991. Discrepancies arose regarding the amount PPC had satisfied to the Municipality, leading to the filing of subsequent motions and an eventual request for a more detailed examination of PPC’s gross sales for tax computation purposes.
Legal Representation Issue
A significant issue emerged when Atty. Felix E. Mendiola filed a motion on behalf of the Municipality for the examination of PPC's gross sales. PPC contested Atty. Mendiola's authority to represent the Municipality, which initiated a cascade of legal proceedings culminating in the Municipality’s petition for certiorari to the Court of Appeals (CA-G.R. SP No. 27504).
Court of Appeals Ruling
On March 31, 1992, the Court of Appeals dismissed the Municipality's petition, stating that it was improperly filed through private counsel in contravention of the law and established jurisprudence. The CA’s ruling highlighted that only a municipal attorney or provincial fiscal can represent a municipality, reaffirming the limitations set forth in Section 1683 of the Revised Administrative Code, which mandates that a municipality can only appoint private attorneys under specific circumstances, none of which were evidenced in this case.
Petitioner’s Arguments
The Municipality, dissatisfied with the CA's dismissal, raised several assignments of error on appeal. These included complaints about the CA considering issues not raised at the trial level, the dismissal of the petition with an admonition to file a proper petition, and assertions regarding the authority of Atty. Mendiola to represent the Municipality.
Supreme Court's Interpretation
The Supreme Court upheld the CA's ruling, concluding that Atty. Mendiola did not have the legal authority to represent the Municipality. Citing previous cases, the Court reiterated that the representation of a municipality in legal matters is limited to its duly appointed officials unless the provincial fiscal is disqualified, which was not demonstrated in this instance. The Court noticed that Mendiola’s involvement was additionally rendered moot by subsequent actions taken by the Municipality which indicated an implied dismissal of Mendiola’s previous representation.
Authority and Revocation of Counsel
The Court importantly noted that a cli
...continue readingCase Syllabus (G.R. No. 105909)
Case Overview
- The case is a petition for review questioning the resolution of the Court of Appeals which dismissed the petition filed by the Municipality of Pililla, Rizal, due to improper representation by a private counsel.
- The decisions in question are dated March 31, 1992 (dismissing the petition) and June 9, 1992 (denying the motion for reconsideration).
Factual Background
- On March 17, 1989, the Regional Trial Court of Tanay, Rizal, ruled in favor of the Municipality of Pililla against Philippine Petroleum Corporation (PPC) in Civil Case No. 057-T, ordering PPC to pay various taxes and fees amounting to approximately P21,455,225.00.
- The Supreme Court affirmed this judgment on June 3, 1991, with modifications regarding the prescription of certain claims and ownership of storage tanks.
- The judgment became final on July 13, 1991, and was remanded for execution.
Execution Issues
- On October 14, 1991, Atty. Felix E. Mendiola filed a motion for examination of PPC’s gross sales for tax computation purposes.
- PPC informed the court that it had already paid the judgment amount of P11,457,907.00, satisfying the court’s order.
- The trial court subsequently denied the municipality's motion for examination, citing that the judgment had been satisfied.
Procedural History
- Following the court's denial, Atty. Mendiola filed a motio