Case Summary (G.R. No. 111357)
Factual Background
The Supreme Court had previously resolved the factual aspects of this case through G.R. No. 63855, which established that Jose and Salvacion Tayengco were the lawful owners of the properties in question, and G.R. No. 60076, which upheld TRB's appointment as receiver pendente lite. These rulings led to the termination of the receivership proceedings, after which TRB presented its final accounting, retaining P219,016.24 as its receiver's fee. The Regional Trial Court of Iloilo approved this accounting on July 5, 1988, a decision contested by the Tayengcos.
Court of Appeals' Decision
The Tayengcos appealed to the Court of Appeals, contending that TRB's fee ought to be charged against the losing party rather than deducted from the funds under receivership. The Court of Appeals, in a decision on February 12, 1993, agreed with the Tayengcos, ruling that TRB could not deduct its fees from the receivership funds and ordered TRB to return the amount to the Tayengcos, holding the losing parties, particularly Cu Bie et al., solely liable for the compensation of the receiver.
TRB's Motion for Reconsideration
TRB subsequently filed a motion for reconsideration, which the appellate court denied on August 17, 1993. In its appeal, TRB presented several errors allegedly made by the Court of Appeals: first, that the appellate court's ruling contradicted the Supreme Court's prior decision in the case of Jose Tayengco vs. Hon. Ilarde; second, that the IAC lacked jurisdiction over CA-GR. 21423 due to the concurrent jurisdiction of the Supreme Court; and third, that the IAC violated the principle of "bar by final judgment."
Res Judicata Analysis
The Supreme Court undertook to resolve two critical issues: whether the Court of Appeals' decision was barred by res judicata and who was responsible for TRB's receiver’s fees. On the first issue, the Court clarified the elements of res judicata — the finality of the previous judgment, jurisdiction, merit, and identity of parties and cause of action. The Court determined that the causes of action in the two cases were distinct, dismissing TRB's argument concerning res judicata.
Compensation of Receiver
The principal query was regarding TRB's right to compensation as a receiver. The Supreme Court reiterated the provisions of Section 8 of Rule 59 of the Revised Rules of Court, which outlines that a receiver's compensation should be a
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Background of the Case
- The case is rooted in the legal ownership of certain properties under receivership, previously settled in G.R. No. 63855, where the deceased spouses Jose and Salvacion Tayengco were recognized as lawful owners.
- The appointment of Traders Royal Bank (TRB) as receiver pendente lite was established as valid in G.R. No. 60076.
- Following these rulings, the receivership proceedings concluded, prompting TRB to render a final accounting of the funds, which included a retention of P219,016.24 as its receiver's fee.
Proceedings in Lower Courts
- On July 5, 1988, the Regional Trial Court of Iloilo, Branch 5, approved TRB's final accounting, including the deduction of its fee from the receivership funds.
- The Tayengcos contested this order in the Court of Appeals, asserting that TRB's compensation should not be deducted from the receivership funds but rather should be charged against the losing party in the underlying case.
Court of Appeals Decision
- On February 12, 1993, the Court of Appeals ruled that TRB could not deduct its fee from the receivership funds, stipulating that the compensation should be borne by the losing parties or shared among the parties-litigants.
- As a result, TRB was ordered to return the P219,016.24 to the Tayengcos, with the losing parties, identified as Cu Bie, et al., held solely responsible for TRB's compensation.