Philippine National Bank v. Honorable Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from a complaint filed by private respondents Clara Reyes Pastor and other stockholders of C & C Commercial Corporation against petitioners Philippine National Bank (PNB) and National Investment Development Corporation (NIDC). The complaint, lodged on October 16, 1973, sought the termination of a Voting Trust Agreement, an accounting, and damages, with a prayer for injunction and receivership. After nineteen years, the trial court rendered a decision on January 20, 1992, rescinding the Voting Trust Agreement, declaring certain loans fully paid by set-off with awarded damages, cancelling real estate mortgages, making a preliminary injunction permanent, and ordering petitioners to pay substantial damages and attorney's fees. Procedural History: A copy of the trial court's decision dated January 20, 1992, was sent by registered mail on January 23, 1992, to the PNB's counsel; however, the mail was received by PNB's mailing clerk from the post office on January 23, 1992, and delivered to the Legal Department on January 28, 1992. Petitioners filed a notice of appeal on February 10, 1992, but the respondent judge denied this appeal, deeming it late, and issued a writ of execution on June 11, 1992, based on the decision becoming final and executory on January 23, 1992. Petitioners then filed a petition for certiorari in the Court of Appeals seeking to nullify the denial of their appeal and the subsequent writ of execution and notice of garnishment, which the Court of Appeals dismissed, leading to the present appeal. The Petition: Petitioners, Philippine National Bank and National Investment Development Corporation, are before the Supreme Court seeking to overturn the Court of Appeals' dismissal of their petition for certiorari, contending that the trial court gravely abused its discretion in holding that the decision dated January 20, 1992, had become final and executory. The core issue presented is whether the petitioners should be deemed to have received the trial court's decision on January 23, 1992, when the mail was collected by their mailing clerk, or on January 28, 1992, when it reached the Legal Department; petitioners anchor their argument on the principle that service is effective only upon actual receipt by the authorized representative, citing precedent, while the lower courts found their argument to be a belated attempt to question a long-standing practice of mail receipt through their mailing division.
Issue(s)
Whether the petitioners are deemed to have received a copy of the trial court's decision on January 23, 1992, when the mail was received by the PNB mailing clerk from the post office, or on January 28, 1992, when it was delivered by the clerk to the Legal Department; and the effect of this on the reglementary period for appeal. Whether the trial court committed a grave abuse of discretion in denying the notice of appeal and issuing a writ of execution.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, holding that the appeal was filed out of time. The Court ruled that the service of the decision was validly made on January 23, 1992, when the PNB mailing clerk, an authorized representative, received the registered mail from the post office. Consequently, the notice of appeal filed on February 10, 1992, was indeed filed beyond the reglementary period.
Ratio Decidendi
On the issue of service of judgment and reglementary period for appeal: The Court held that the service of the decision was validly made on January 23, 1992. The mailing clerk of the Philippine National Bank (PNB), Mr. Catalino M. Sandoval, who was permanently assigned to the PNB's Mailing Division, General Services Department, was authorized to collect all PNB mailing matters. Although not detailed with the PNB Legal Department, Mr. Sandoval had been receiving orders and notices for petitioners for years and signing the corresponding registry return cards without complaint. The Court emphasized that the PNB employee was duly authorized to receive mails for the bank. The fact that the mailing clerk received the mail from the post office on January 23, 1992, signifies receipt by the PNB. The subsequent delay in delivery to the Legal Department was an internal matter of the bank and did not affect the validity of the service. The Court distinguished this case from PLDT vs. NLRC, where the notice was left on the ground floor instead of the lawyer's address of record. Here, the mail was received by an authorized employee of the addressee's organization. The judge correctly determined that the appeal was filed out of time based on the valid service of the decision on January 23, 1992. The notice of appeal was filed on February 10, 1992, which was 18 days after January 23, 1992, exceeding the 15-day reglementary period. On the issue of grave abuse of discretion: The Court found no grave abuse of discretion on the part of the trial judge. The Court noted that the petitioners' counsel had consistently received previous court orders and notices through the same mailing division and had honored them without question. Therefore, the counsel was estopped from questioning the validity of the service of the decision on the grounds of an alleged procedural defect in internal mail handling. The Court stressed that allowing such a claim would allow parties to dictate when a decision becomes effective, leading to chaos in the administration of justice. The negligence of the mailing clerk in not promptly delivering the mail to the Legal Department was attributable to the Legal Department and its counsel.
Main Doctrine
Service of court processes, including judgments, through registered mail is deemed complete upon receipt by the authorized mailing clerk or division of the addressee, even if it is subsequently delayed in reaching the intended recipient within the organization, as the mailing clerk is considered an authorized representative for receiving such mail. Failure to question the validity of service of prior notices received through the same channel estops the party from questioning the service of the judgment.