Case Summary (G.R. No. L-60687)
Background Facts
BBI had been providing janitorial maintenance and sanitation services to PLDT for over a decade. In 1977, due to rising prices and increased labor costs mandated by the Labor Code and various Presidential Decrees, BBI requested a readjustment of its monthly billing rates. PLDT agreed to a lower amount of P550.00 per month per janitor on September 18, 1978. Subsequently, BBI claimed that PLDT had only paid a portion of the amount due, leading to a balance of P212,624.78. In February 1981, BBI filed a complaint against PLDT for the outstanding balance along with additional claims.
Judicial Proceedings
Commencing with a pre-trial on October 15, 1981, the trial court allowed BBI to present its documentary evidence, leading to the scheduling of subsequent hearings. PLDT’s attempts to postpone the trial due to the sudden illness of its witness were rejected. Consequently, on April 27, 1982, the court issued a favorable decision for BBI, ordering PLDT to pay the total amount claimed, including attorney’s fees and costs.
PLDT's Motion for Reconsideration
Following the ruling, PLDT filed a motion for a new trial and/or reconsideration on May 27, 1982, claiming it was not liable for the amounts asserted and was denied the opportunity to present its evidence. Concurrently, BBI filed a motion for immediate execution based on PLDT’s alleged dilatory conduct.
Issuance of Execution Pending Appeal
On June 7, 1982, the respondent judge denied PLDT’s motion for reconsideration and granted BBI’s motion for immediate execution. The judge justified this on the basis of perceived delays by PLDT in the litigation process and alleged admissions of liability. Subsequently, a writ of execution was issued on June 8, 1982. PLDT then filed a petition for certiorari, contesting the validity of the orders granting immediate execution.
Legal Analysis of Execution Pending Appeal
The court found that the trial judge had erred in issuing the writ of execution pending appeal, as there were no "good reasons" that warranted such a decision. The mere existence of delays or suspicions of a dilatory appeal did not suffice to justify the issuance of execution pending appeal. The court stressed that the merits of PLDT's appeal had not yet been decided, and the assumption of liability based solely on procedural timelines lacked proper legal foundation.
Approval of Bill of Costs
Additionally, the approval of BBI’s bill of costs by the trial judge was deemed as having been made with grave abuse of discretion. The ruling highlighted that since PLDT had appealed, the judgment was not yet final
...continue readingCase Syllabus (G.R. No. L-60687)
Case Overview
- The case involves the Philippine Long Distance Telephone Company (PLDT) as the petitioner against Judge Minerva C. Genovea, Sheriff Romulo Victoria, and Better Buildings, Inc. (BBI) as respondents.
- The petition seeks the annulment of an order dated June 7, 1982, which authorized the execution of a judgment during the appeal process.
- The case centers on a civil suit (Civil Case No. 39943) where BBI sought payment from PLDT for services rendered.
Background of the Case
- BBI had provided janitorial services to PLDT for over ten years and requested a readjustment of monthly billings due to rising costs and mandated employee benefits.
- PLDT agreed to a reduced billing of P550.00 per month for each janitor but allegedly failed to pay the total sum due, leading BBI to file a complaint for the outstanding amounts.
- In its defense, PLDT claimed BBI was an independent contractor responsible for its employees and denied any liability exceeding the agreed amount.
Pre-Trial and Trial Proceedings
- The pre-trial was held on October 15, 1981, where the judge allowed BBI to present its documentary evidence and set the case for trial.
- On January 6, 1982, the judge admitted all of BBI's evidence despite objections from PLDT.
- PLDT's request for postponement on March 18, 1982, was denied, leading to PLDT waiving its right to present its evidence.
- The trial concluded with a judgment on April 27, 1982, ordering PLDT to pay BBI various amounts totalin