Mirafuentes v. Sabellano
REITERATIONFacts
The Antecedents: In Civil Case No. 817, the Court of First Instance of Misamis Occidental rendered a decision in favor of the plaintiffs (Mirafuentes) against the defendant (Sabellano), granting them the right to redeem a parcel of land by paying P1,000. The decision ordered the defendant to execute a deed of resale and deliver possession upon payment. Victorio Sabellano filed a supersedeas bond for P6,000 with Cristino G. Abasolo and Teofilo Pereyra as sureties to stay execution. Procedural History: The Court of Appeals affirmed the decision of the Court of First Instance in toto. Subsequently, the plaintiffs filed a complaint against Victorio Sabellano, Cristino G. Abasolo, and Teofilo M. Pereyra for damages amounting to P6,000, representing the alleged use and occupation of the litigated land by Sabellano. The trial court ruled that the supersedeas bond was answerable for these damages and sentenced the defendants jointly and severally to pay P2,000 with legal interest. The Appeal: The defendants appealed the decision of the trial court, arguing that they are not liable for the damages awarded because the supersedeas bond was conditioned only on the affirmance of the original judgment, which did not include any award for damages. They contended that their liability, if any, was limited to the terms of the original decision and the bond.
Issue(s)
Whether the sureties on a supersedeas bond are liable for damages for the use and occupation of the property litigated, when such damages were not awarded in the original judgment affirmed by the appellate court. Whether the supersedeas bond, conditioned on the affirmance of the judgment, can be held answerable for claims not included in the affirmed judgment.
Ruling
The appealed decision is reversed, and the defendants are absolved from the complaint, without costs. The Court ruled that the supersedeas bond is not answerable for the damages claimed.
Ratio Decidendi
On Issue 1: The Court ruled that the appellants (sureties) are not liable for the damages claimed. Under Section 2 of Rule 39 of the Rules of Court, a supersedeas bond stays execution pending appeal and is conditioned upon the performance of the judgment or order appealed from in case it is affirmed. The bond in this case was conditioned for the payment of any sum due by reason of the affirmance of the decision. Since the original decision, as affirmed by the Court of Appeals, did not award any damages or costs to the plaintiffs, there remained nothing for the defendant Sabellano to pay under that judgment, and consequently, nothing for the sureties to answer for. On Issue 2: The contention that the bond is contractual and therefore liable for damages apart from the affirmed adjudication was dismissed. The Court emphasized that the wording of the bond clearly indicated its purpose was to secure the performance of the appealed decision. Section 3 of Rule 39 also implies that liability under the bond arises from the appealed judgment in the same case. Therefore, claims for damages not awarded in the affirmed judgment fall outside the scope of the supersedeas bond's coverage, and the sureties cannot be held liable for them.
Main Doctrine
A supersedeas bond, filed to stay execution pending appeal, is conditioned upon the performance of the judgment or order appealed from in case it is affirmed wholly or in part. The liability of the sureties is strictly confined to the amount or performance stipulated in the affirmed judgment. If the original decision, as affirmed, does not award damages, the sureties cannot be held liable for damages arising from the use and occupation of the property during the pendency of the appeal, as such claims are outside the scope of the bond's undertaking.