Congressional Commercial Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Spouses Higino R. Francisco and Norberta Gana leased two adjoining lots in Quezon City to Congressional Commercial Corporation (CCC) for twenty years, commencing August 31, 1971. The lease agreement stipulated staggered monthly rentals and included a clause linking rental adjustments to inflation or deflation, to be indicated by changes in the moviehouse's entrance ticket price, with a base price of P1.75 for an orchestra seat. CCC constructed and operated the Cubao Cinema on the leased premises. The lessors sought an upward adjustment of rentals, citing a decrease in the peso's value and an increase in ticket prices to P2.00 and later P2.25, which CCC refused, asserting that no official declaration of inflation by the Central Bank had been made. 2. Procedural History: The Franciscos filed a petition for declaratory relief in the Court of First Instance of Rizal, seeking adjusted rentals based on increased ticket prices and questioning the necessity of an official Central Bank declaration of inflation. CCC and Bienvenido Lim argued that the contract terms were clear and that no inflation had been officially declared. After CCC and Lim were declared in default for failing to appear at pre-trial, the lower court ruled in favor of the Franciscos, ordering adjusted rentals. CCC and Lim's subsequent petition for relief from default and their appeal to the Court of Appeals were denied. The Court of Appeals affirmed the lower court's decision with modifications, clarifying that CCC's president was not personally liable and that the rental increase clause had effectively superseded another provision. CCC and Lim then filed multiple motions for extensions and a motion for reconsideration, which were denied, leading to the finality and executory nature of the decision. Despite this, CCC and Lim filed the instant petition with this Court. 3. The Petition: Petitioners Congressional Commercial Corporation and Bienvenido Lim filed this petition for review on certiorari and/or original petition for certiorari under Rule 45 and/or Rule 65 of the Rules of Court. They seek to nullify the decisions of the trial and appellate courts, arguing that the judgments were rendered without sufficient evidence and thus violated substantive due process. Petitioners contend that the Court of Appeals erred in its computation of rental increases and in denying their motions for reconsideration. They also argue that the appellate court's decision was not in accord with established jurisprudence and that the lower courts acted with grave abuse of discretion. The petition also questions the interpretation of the lease contract regarding the basis for rental adjustments, specifically whether it referred to the lessee's moviehouse ticket prices or general increases in moviehouse ticket prices.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's decision despite the alleged lack of jurisdiction and denial of substantive due process. Whether the petition for review on certiorari and/or original petition for certiorari is the proper remedy given that the decision sought to be reviewed had already become final and executory. Whether the petitioners are estopped from appealing the decision of the Court of Appeals due to their actions. Whether the Court of Appeals committed grave abuse of discretion in denying the motion for reconsideration of its resolution clarifying the computation of rentals.
Ruling
The Supreme Court dismissed the petition and lifted the temporary restraining order. The Court held that the decision of the Court of Appeals had long become final and executory when the petition was filed. The Court also found that the petitioners were estopped from appealing due to their actions, including consigning a partial payment in satisfaction of the judgment. The remedy of certiorari was deemed unavailable as the petitioners had lost their remedy by appeal.
Ratio Decidendi
On the alleged error of the Court of Appeals: The Court found no error. The Court reiterated that a party who voluntarily executes a judgment is not permitted to appeal from it. The petitioners' act of consigning a sum of money in satisfaction of the judgment, even with a reservation, constituted an acquiescence to the judgment, thereby precluding them from appealing. On the availability of appeal and certiorari, and the finality of the judgment: The petition for certiorari was dismissed because the remedy by appeal had been lost. Certiorari is not a substitute for a lost appeal, especially when the lower court had jurisdiction over the subject matter. The Court emphasized that the decision of the Court of Appeals was promulgated on December 8, 1980, and declared final and executory on February 20, 1981, after the petitioners failed to file their motion for reconsideration despite extensions. Entry of judgment was made on the same date. The subsequent actions of the Court of Appeals in clarifying its decision did not revive the case but merely exercised its inherent power to clarify its own judgment. Therefore, when the petitioners filed their appeal on December 28, 1981, the decision sought to be reviewed had long become final and executory. On the issue of estoppel: The Court found that the petitioners were estopped from appealing the decision of the Court of Appeals. Their act of consigning ₱41,958.00 under cashier's check payable to Higino Francisco for and "in satisfaction of the Honorable Court’s judgment" was a clear recognition of the private respondents' entitlement to an increase in rentals. This act, performed during the pendency of their motion for reconsideration, bound them to the judgment, except possibly on their reservation regarding the basis of the increase. On the alleged grave abuse of discretion and the petitioners' procedural missteps: The Court found no grave abuse of discretion on the part of the Court of Appeals in denying the motion for reconsideration of its resolution. The new matters raised by the petitioners in that motion were matters of defense that should have been raised earlier in their petition for relief from judgment, their appeal, or at any stage thereof, not at such a belated stage of the proceedings. The appellate court correctly ruled that these new matters could not be considered at such a late stage. The Court highlighted the petitioners' consistent pattern of negligence and procedural missteps throughout the case, from their initial delay in filing an answer, to the unclaimed notice of pre-trial, to the repeated extensions for filing briefs and motions for reconsideration. These actions demonstrated a failure to exercise ordinary diligence and a disregard for procedural rules, which ultimately led to the finality of the judgment against them.
Main Doctrine
A party who voluntarily executes, either partially or in toto a judgment rendered for or against him, or who voluntarily acquiesces in, or ratifies, either partially or in toto, the execution of that judgment is not permitted to appeal from it. Furthermore, a petition for certiorari will not lie where the remedy by appeal has been lost because said remedy cannot take the place of an appeal.