Joson v. Crisostomo
REITERATIONFacts
The Antecedents: Magdalena S. Joson (petitioner) filed a collection case against spouses Fortunato Crisostomo and Imelda R. Rodriguez (private respondents) with the City Court of Manila. The City Court ruled in favor of Joson, ordering the Crisostomos to pay P5,000.00 with interest, attorney's fees, and costs. Procedural History: The Crisostomos appealed to the Court of First Instance (CFI) of Manila. The CFI rendered a decision sentencing the defendants jointly and severally to pay P5,333.50 with interest, attorney's fees, and costs. Petitioner Joson then filed motions for immediate execution pending appeal and for correction of a typographical error. The CFI granted both motions. Subsequently, the CFI issued orders considering the motion for reconsideration abandoned and ordering the issuance of a writ of execution pending appeal upon filing of a P15,000.00 bond. The Petition: The Crisostomos filed a petition for certiorari with preliminary injunction with the Court of Appeals (CA) against the CFI Judge and Joson, assailing the orders for execution pending appeal. The CA set aside the CFI's orders. Joson, assisted by her husband, filed the present petition for review on certiorari with the Supreme Court, questioning whether the CFI Judge issued the order for execution pending appeal with grave abuse of discretion.
Issue(s)
Whether the order for the execution of the judgment pending appeal was issued by the Honorable Francisco Geronimo with grave abuse of discretion.
Ruling
The Supreme Court dismissed the petition for being moot and academic.
Ratio Decidendi
On Issue 1: The Supreme Court noted that the Court of Appeals had affirmed the CFI's decision, which became final and executory. Given that the main case had already been decided on its merits, affirmed on appeal, and had become final and executory, the issue of whether the execution pending appeal was granted with grave abuse of discretion had become moot and academic. Therefore, the petition for review on certiorari was dismissed on this ground.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari assailing an order for execution pending appeal becomes moot and academic if the main case has already been decided on its merits, affirmed by the Court of Appeals, and has become final and executory. The subsequent final resolution of the main case renders the issue of whether the execution pending appeal was granted with grave abuse of discretion moot.