Case Summary (G.R. No. 193945)
Antecedent Facts
On August 1, 1984, Remington filed a complaint against Marinduque Mining and Industrial Corporation (MMIC) for the recovery of P921,755.95 representing unpaid purchases of construction materials, leading to the inclusion of various banks and corporations as co-defendants. The Regional Trial Court (RTC) ruled in favor of Remington on April 10, 1990, ordering all defendants to pay the sum due, including interest and attorney’s fees. The subsequent appellate process involved several rulings, including the confirmation of the RTC decision by the Court of Appeals (CA) on October 6, 1995.
Judicial Proceedings and Outcomes
After multiple appeals, including attempts by PNB and DBP to contest the RTC decision, a significant ruling was issued by the Supreme Court on February 11, 2008, which ultimately annulled the execution orders issued by the RTC related to the case. Following this, on December 19, 2008, Remington's motion for execution against Maricalum was denied by the RTC, citing the principle of immutability of final judgments.
Court of Appeals Ruling
On April 26, 2010, the CA overturned the RTC's decision, ordering Remington to return garnished amounts to Maricalum, including interest until full payment. The CA asserted that the dismissal of the initial complaint against PNB and DBP constituted a "supervening event," which removed liability from Maricalum for MMIC's debts, thereby necessitating restitution.
Remington's Arguments
Remington argued that the decisions from the RTC and CA had long been settled and deemed final, maintaining that Maricalum's litigation approach contradicted the established principle of immutability of final judgments. It contended that the CA’s recognition of "supervening events" was misapplied, as such events could not retroactively affect already executed judgments.
Maricalum’s Defense
Maricalum asserted that the prior Supreme Court decision effectively annulled any execution orders against it, thereby requiring the return of garnished funds. They emphasized that no liability existed following the dismissals and that the RTC’s orders had lost their legal basis.
Supreme Court's Ruling
The Supreme Court affirmed the CA's decision, stating that the initial RTC ruling had become final and executory vis-à-vis Maricalum, but the following annulments and rulings constituted a legitimate supervening event that precluded the execution of judgments against Maricalum. The Court emphasized the implications of the earlier rulings on the relationship between the parties and the necessity for restitution to uphold justice and equity based on the principle of reversibil
...continue readingCase Syllabus (G.R. No. 193945)
Case Background
- The case concerns a review of the Decision dated April 26, 2010, and the Resolution dated September 30, 2010, issued by the Court of Appeals (CA) in CA-G.R. SP No. 110178.
- The CA reversed and set aside the Order dated December 19, 2008, of the Regional Trial Court (RTC) of Manila, Branch 19, in Civil Case No. 84-25858.
- The CA ordered petitioner Remington Industrial Sales Corporation (Remington) to return and restitute to respondent Maricalum Mining Corporation (Maricalum) the garnished amounts of P920,755.95 and P32,256.48, along with an interest of 12% per annum until fully satisfied.
Antecedent Facts
- On August 1, 1984, Remington filed a complaint against Marinduque Mining and Industrial Corporation (MMIC) for unpaid purchases of construction materials, amounting to P921,755.95, with an annual interest of 18%.
- The complaint was later amended to include Philippine National Bank (PNB), Development Bank of the Philippines (DBP), Nonoc Mining and Industrial Corporation, Maricalum, Island Cement Corporation, and Asset Privatization Trust as defendants.
- The RTC rendered a Decision on April 10, 1990, in favor of Remington, holding all defendants jointly and severally liable for the amount with a penalty of 10% per annum until fully paid.
- The CA affirmed this decision on October 6, 1995, but subsequent appeals by PNB and DBP led to a series of rulings that ultimately dismissed Remington's complaint against them, impacting Maricalum's liability.
Execution and Garnishment
- Following various legal maneuvers, the RTC issued a writ of execu