Case Summary (G.R. No. 186063)
Factual Background
On July 1, 1996, Goroza entered into an Exclusive Dealership Agreement with SMC. He subsequently applied for a credit line with PNB, which included obtaining a letter of credit. Initially using this credit line effectively, Goroza began experiencing payment difficulties in January 1998 due to accumulating debts, leading to a failure to settle his obligations to SMC amounting to approximately three million seven hundred twenty-two thousand four hundred forty pesos and 88/100 (P3,722,440.88). Consequently, on April 23, 2003, SMC initiated a legal action against both Goroza and PNB for the collection of the unpaid amounts.
Trial Court Proceedings
Upon being summoned, PNB filed an Answer, while Goroza failed to respond, leading to a declaration of default against him. An ex parte trial focused on Goroza commenced, resulting in a May 10, 2005 decision wherein the RTC ruled in favor of SMC, ordering Goroza to pay the principal amount plus interest, attorney's fees, and litigation expenses. Goroza filed an appeal, while SMC sought a reconsideration of the court’s judgment, obtaining an amended ruling that increased litigation expenses.
Supplemental Judgment and Amended Order
As the case advanced, PNB attempted to terminate proceedings, arguing that the RTC’s ruling against Goroza had resolved the obligations owed to SMC. However, the RTC issued a supplemental judgment on October 14, 2005, clarifying that the judgment against Goroza did not preclude ongoing proceedings against PNB. PNB’s motion for reconsideration was denied, prompting it to seek certiorari from the Court of Appeals, arguing that the trial court acted with grave abuse of discretion.
Court of Appeals' Decision
On June 17, 2008, the Court of Appeals affirmed the RTC’s decision, determining that the trial court properly exercised jurisdiction. It concluded that the proceedings against PNB could continue independently of Goroza's appeal, emphasizing that Goroza's obligations were separate from PNB's potential liabilities under the letters of credit issued during their financial dealings.
Legal Principles Involved
PNB contended that the RTC had lost jurisdiction over the case upon Goroza’s perfecting of his appeal. However, the appellate court held that both the trial court's procedures and the adoption of separate judgments against the defendants were permissible under Section 4, Rule 36 of the Rules of Court, recognizing the distinct nature of the legal obligations owed by Goroza and PNB. The underlying rationale
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Case Overview
- This case concerns a petition for review on certiorari involving the Philippine National Bank (PNB) as the petitioner and San Miguel Corporation (SMC) as the respondent.
- The petition arose from the decisions and resolutions of the Court of Appeals (CA) dated June 17, 2008, and December 15, 2008, which affirmed earlier rulings by the Regional Trial Court (RTC) of Butuan City.
Facts of the Case
- On July 1, 1996, SMC entered into an Exclusive Dealership Agreement with Rodolfo R. Goroza, granting him rights to sell various beer products.
- Goroza required a letter of credit to access a credit line from SMC, which was facilitated by PNB, granting him P2,000,000.00.
- Goroza subsequently applied for and was granted an additional credit line totaling P4,400,000.00.
- Initially, Goroza met his payment obligations; however, by January 1998, he began defaulting, leading to SMC demanding payment of P3,722,440.88 from both Goroza and PNB.
- On April 23, 2003, SMC filed a complaint against PNB and Goroza for collection in the RTC.
Proceedings in the Regional Trial Court
- After Goroza was declared in default for not responding to the complaint, SMC presented evidence against him ex parte.
- The RTC ruled in favor of SMC on May 10, 2005, ordering Goroza to pay the principal amount, interest, attorney's fees, and litigation expenses.
- Goroza filed a notice of appeal, while SMC sough