Mindanao Terminal v. Philippine Ports Authority
REITERATIONFacts
The Antecedents: The Philippine Ports Authority (PPA) sued Mindanao Terminal and Brokerage Service, Inc. (MINTERBRO) for its 10% share in MINTERBRO's gross income from port-related services. The Regional Trial Court (RTC) ruled in favor of PPA, ordering MINTERBRO to pay ₱36,585,901.18. Procedural History: The Court of Appeals (CA) affirmed the RTC decision. MINTERBRO received the CA decision via registered mail on December 4, 2002. The decision became final and executory on December 20, 2002. MINTERBRO's counsel, Atty. Rafael S. Dizon, filed a Motion for Reconsideration of the Declaration of Finality and to Set Aside Entry of Judgment, claiming non-receipt of the decision. The CA denied this motion. PPA sought execution of the judgment, but the RTC, through Judge Cesar M. Solis, held execution in abeyance, first pending resolution by the CA, and later by the Supreme Court. The RTC also issued a Status Quo Ante Order compelling PPA to renew MINTERBRO's permit despite pending issues. The Petition: MINTERBRO filed a petition for certiorari (G.R. No. 163286) assailing the CA Resolution denying its motion for reconsideration. PPA filed petitions for certiorari (G.R. No. 166025 and G.R. No. 170269) assailing the RTC Orders that held execution in abeyance and issued the Status Quo Ante Order.
Issue(s)
Whether the Court of Appeals Decision dated 21 November 2002 had become final and executory and whether it was properly served on MINTERBRO’s counsel. Whether the RTC committed grave abuse of discretion amounting to lack or in excess of jurisdiction when it refused to implement/execute its 28 August 1990 Decision which had already become final and executory, in the absence of an injunction or temporary restraining order from higher courts. Whether the RTC committed grave abuse of discretion when it resolved issues alien to the main case and supplanted PPA’s constitutionally protected right to contract.
Ruling
The Supreme Court held that the Court of Appeals Decision dated 21 November 2002 had become final and executory. It directed the RTC to issue the writ of execution and nullified the RTC Orders granting MINTERBRO's Motion for Issuance of Status Quo Ante Order and related subsequent orders.
Ratio Decidendi
On whether the Court of Appeals Decision dated 21 November 2002 had become final and executory and whether it was properly served on MINTERBRO’s counsel: The Court ruled that service of judgment by registered mail is complete upon actual receipt by the addressee or five (5) days from the date of receipt of the first notice from the postmaster, whichever is earlier. The records showed that registered letter No. 6270-B was received by Virgie Cabrera at the stated address on December 4, 2002. The Court found that Atty. Dizon had a responsibility to inform the Court of Appeals of his change of address, which he only did on November 12, 2003, almost a year after the entry of judgment. His motion for reconsideration filed prior to informing the court of his new address still bore the old address where the decision was delivered. Therefore, the service was considered proper, and the decision became final and executory on December 20, 2002. On whether the RTC committed grave abuse of discretion when it refused to implement/execute its 28 August 1990 Decision: The Court held that once a judgment becomes final, the prevailing party is entitled as a matter of right to a writ of execution. The issuance of such a writ is a ministerial duty of the court. The RTC abused its discretion by holding the execution in abeyance, first pending resolution by the Court of Appeals and then by the Supreme Court, without any injunction or temporary restraining order. The mere pendency of a petition for certiorari does not interrupt the course of proceedings in the lower court. The RTC's modification of its order to hold execution in abeyance until the Supreme Court resolved the petition, instead of the Court of Appeals as initially stated, was also noted as a deviation. On whether the RTC committed grave abuse of discretion when it resolved issues alien to the main case and supplanted PPA’s constitutionally protected right to contract: The Court found that the RTC gravely abused its discretion when it issued a Status Quo Ante Order compelling PPA to act on MINTERBRO's permit application and to cease imposing requirements. The RTC lost jurisdiction over the substantive issues of the case upon the perfection of the appeal to the Court of Appeals. The residual jurisdiction of the trial court to issue orders for the protection and preservation of the rights of the parties, as provided under Section 8(a), Rule 42 of the Rules of Court, is applicable only before the appellate court gives due course to the petition. At the time the Status Quo Ante Order was issued, the Supreme Court had already taken over jurisdiction, and even the Court of Appeals had lost jurisdiction over the issue of finality of the decision. The RTC's actions encroached upon PPA's right to contract and its regulatory functions.
Main Doctrine
Service of judgment by registered mail is complete upon actual receipt by the addressee or five (5) days from the date of receipt of the first notice from the postmaster, whichever is earlier. A party's failure to inform the court of a change of address does not negate the validity of service made at the last known address. The mere pendency of a petition for certiorari does not interrupt the course of proceedings in the lower court without a restraining order or injunction.