Republic v. Mendiola
REITERATIONFacts
The Antecedents: On May 21, 2001, the Manila International Airport Authority (MIAA) entered into a Contract of Lease and Concessions with Little Vin-Vin's Food Corporation (LVV) for the operation of retail and catering outlets at NAIA Centennial Airport Terminal II. LVV was granted six months to complete required works, but requested extensions due to insufficient power supply, which MIAA did not fully address. This led LVV to file a complaint for specific performance, seeking rectification of electrical defects at MIAA's cost, an extension of the construction period, and the offsetting of expenses against rentals. Procedural History: The Regional Trial Court (RTC) of Pasay City, Branch 115, issued a partial summary judgment on August 19, 2003, ordering MIAA to rectify electrical facilities and grant LVV an extension of the construction period, suspending rentals in the interim. LVV later filed a supplemental complaint alleging MIAA's failure to meet passenger forecasts, refusal to deliver a specific area, and barricading of access, causing damages. On April 26, 2004, the RTC issued another partial summary judgment, granting LVV a proportionate reduction of rental payments and awarding nominal damages. Further orders on July 14 and July 15, 2004, directed MIAA to offset LVV's electrical installation expenses against rentals and allowed adherence to Administrative Order No. 1 for rent reduction calculations. MIAA filed a Notice of Appeal on December 15, 2004, which the RTC denied for being filed out of time. The Court of Appeals dismissed MIAA's subsequent petition for certiorari, prompting the present petition. The Petition: The petitioner, Republic of the Philippines represented by MIAA, seeks review on certiorari of the Court of Appeals' decision, arguing that its Notice of Appeal was perfected within the reglementary period. The core issue is whether the trial court's July 15, 2004 Order, which was entered into the Book of Entries of Judgment on August 10, 2004, was a final or interlocutory order. Petitioner contends that the July 15, 2004 Order was not final as it did not resolve all issues, specifically those concerning LVV's unearned earnings and attorney's fees, making its entry into the judgment book premature and void. Therefore, the subsequent Notice of Appeal should have been considered timely filed.
Issue(s)
Whether the Notice of Appeal filed by petitioner MIAA was filed within the reglementary period. Whether the Order of July 15, 2004, was a final judgment or an interlocutory order.
Ruling
The petition is GRANTED. The recording of the July 15, 2004 Order in the Book of Entries of Judgment of Branch 115 of the Regional Trial Court of Pasay City is declared NULL AND VOID. The assailed October 17, 2006 Decision of the Court of Appeals is REVERSED and SET ASIDE. The case is REMANDED to the Court of Appeals for resolution of petitioner’s appeal.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petitioner's Notice of Appeal was filed on time. The Court clarified that the reglementary period for appeal begins to run only from the notice of the final judgment or order that resolves all the issues in the case. The trial court's Order of July 15, 2004, was not a final judgment because it did not dispose of all the issues, specifically the claims for LVV's unearned earnings and attorney's fees. Therefore, its entry into the Book of Entries of Judgment on August 10, 2004, was premature and void. The issues regarding lost earnings and attorney's fees were only considered disposed of when the trial court noted LVV's voluntary desistance on November 23, 2004. Consequently, MIAA's notice of appeal, filed after the final resolution of all issues, was within the reglementary period. On Issue 2: The Supreme Court ruled that the Order of July 15, 2004, was an interlocutory order, not a final judgment. The Court reiterated the test for determining finality: an order is final if it leaves nothing more to be done in the trial court with respect to the merits of the case; otherwise, it is interlocutory. The July 15, 2004 Order did not resolve the claims for unearned earnings and attorney's fees, which were substantial matters that remained pending. Therefore, it did not finally dispose of the entire controversy or a definite and separate branch thereof. The premature entry of this interlocutory order into the Book of Entries of Judgment was void, as only final judgments can be entered therein. The Court emphasized that the premature entry of an order that does not fully resolve the merits of the case renders the entry void and does not start the reglementary period for appeal.
Main Doctrine
An order that does not dispose of all the issues in a case is interlocutory and cannot be the subject of an appeal. Its premature entry into the Book of Entries of Judgment is void. The filing of a notice of appeal from such an order is considered timely if filed after the final resolution of all issues.