Philippine National Bank v. Romillo, Jr.
REITERATIONFacts
1. The Antecedents: Private respondents sought to recover from petitioner Philippine National Bank (PNB) a percentage of their alleged excess payment in Land Bank Bonds. They contended that PNB had no legal right to discount the value of these bonds, which were used to settle a loan and release a mortgage on their Manila property, and that the bonds should have been accepted at face value. PNB countered that Section 80 of P.D. 251 was inapplicable, that accepting Land Bank bonds was at its discretion, and that the private respondents were estopped from questioning the discount due to prior agreement. 2. Procedural History: The Regional Trial Court, Branch CX, Pasay City, ruled in favor of the private respondents on June 18, 1984, ordering PNB to pay P63,205.21 with interest, attorney's fees, and costs. Both parties appealed. Private respondents appealed to the Supreme Court regarding the denial of moral and exemplary damages and the admission of certain exhibits. PNB filed a notice of appeal, initially indicating an appeal to the Intermediate Appellate Court (IAC) due to factual issues, but later, a motion to dismiss PNB's appeal was filed, arguing it should have been directed to the Supreme Court as it involved a pure question of law. PNB opposed this, asserting factual issues were present. The respondent Judge dismissed PNB's appeal on December 20, 1984, and denied reconsideration, prompting PNB to file the present certiorari and mandamus action. 3. The Petition: PNB, as petitioner, filed this action for certiorari and mandamus, seeking to annul the respondent Judge's order dismissing its appeal to the Intermediate Appellate Court. PNB argues that the respondent Judge erred in concluding that its appeal involved only a question of law, asserting that it raised several factual issues before the trial court. PNB contends that the determination of whether an appeal involves questions of law or fact should be left to the appellate court, not the trial court. Furthermore, PNB invokes established jurisprudence that when parties appeal to different appellate courts, the case should be referred to the IAC if factual issues are raised, and that a trial court cannot dismiss an appeal on the ground of being misdirected or frivolous. PNB seeks to have its appeal given due course by the IAC.
Issue(s)
Whether the respondent Judge erred in dismissing petitioner's appeal on the ground that the case was decided on a pure question of law. Whether the respondent Judge erred in dismissing petitioner's appeal on the ground that it was filed with the wrong appellate court. Whether the respondent Judge erred in dismissing petitioner's appeal instead of certifying it to the proper court.
Ruling
The petition for certiorari and mandamus is granted. The order of the respondent Judge dismissing petitioner's appeal and the order denying its motion for reconsideration are annulled and set aside. Respondent Judge is directed to give due course to petitioner's appeal and elevate the records to the Intermediate Appellate Court.
Ratio Decidendi
On the issue of whether the respondent Judge erred in dismissing petitioner's appeal on the ground that the case was decided on a pure question of law: The Court held that the respondent Judge erred in dismissing the appeal based on his misconception that the case involved only a pure question of law. The records showed that petitioner bank raised several factual issues before the trial court, including whether the plaintiffs voluntarily offered to sell their properties, whether the loan was new, whether plaintiffs knew the bank's policy on accepting bonds, whether the bank followed its policy, the absence of a law determining bond valuation, and the timing of the property release from mortgage. The Court emphasized that the determination of whether an appeal involves only questions of law or both questions of fact and law should be left to the appellate court, not the trial court that rendered the decision being appealed. Therefore, as questions of fact and law were intended to be raised, the proper forum for the appeal was the Intermediate Appellate Court. On the issue of whether the respondent Judge erred in dismissing petitioner's appeal on the ground that it was filed with the wrong appellate court: The Court found that the respondent Judge committed a grave error in dismissing the appeal on the ground that it was misdirected. The Court reiterated the established rule that when parties address their appeals to different appellate courts (private respondents to the Supreme Court and petitioner to the IAC), the appeal should be referred to the Court of Appeals. The trial court cannot prevent a party from elevating a challenge to its decision by restricting its own decision to a resolution of a question of law and then denying the appeal to a court where factual issues can be reviewed. The respondent Judge should have allowed the IAC to decide whether the appeal involved only a question of law. On the issue of whether the respondent Judge erred in dismissing petitioner's appeal instead of certifying it to the proper court: The Court pointed out that the respondent Judge acted in complete disregard of Section 3 of Rule 50 of the Rules of Court, which provides that if an appealed case has been erroneously brought to the Court of Appeals, it shall not dismiss the appeal but shall certify it to the proper court. The Court stated that it is not within the province of the lower court to declare an appeal frivolous or dilatory; this duty devolves upon the appellate court. By dismissing the appeal outright, the trial court encroached upon the prerogative of the IAC to certify the appeal to the Supreme Court or to hear the case itself. Even assuming, arguendo, that the respondent Judge's position on the merits was correct, his dismissal of the appeal was still improper; he should have given due course to the appeal and left it to the IAC to certify it to the Supreme Court if warranted.
Main Doctrine
A trial court may not arrogate unto itself the determination of whether an appeal involves only a question of law or both questions of fact and law; this determination is best left to the appellate court. Consequently, a trial court commits a grave error in dismissing an appeal on the ground that it was misdirected to the wrong appellate court based on its own misconception of the nature of the issues raised.