Cited Laws
TL;DR — Ruling
The case was assigned to a new MTC judge, who was then tasked with ruling on the Notice of Appeal.
Accordingly, the MTC declared that its earlier judgment dated 13 January 1998 had become final and executory. In the same order and upon the same predicates, the MTC also granted the Motion for Issuance of Writ of Execution filed by respondent. Petitioner responded to the foregoing developments by filing a Notice of Appeal, as well as a motion for the inhibition by the MTC judge which motion was immediately granted. The case was assigned to a new MTC judge, who was then tasked with ruling on the Notice of Appeal. It was only on 28 September 1999, or eighteen (18) months after the Notice of Appeal was filed, that the MTC acted on the same and ruled that it had been filed beyond the reglementary period. Again, the MTC reiterated that the Judgment dated 13 January 1998 had long become final and executory since the fatally defective Motion for Reconsideration did not toll the reglementary period for appeal. [6] What then followed was a series of unsuccessful attempts by petitioner to have the lower courts set aside or stay the now-final judgment against it. First, petitioner filed a Petition for Relief from Judgment with the MTC on 25 October 1999. [7] This was denied by the MTC in an Order [8] dated 13 March 2000 on the ground that it had been filed out of time. The MTC explained that the petition for relief from judgment must have been filed either within sixty (60) days from the date petitioners new counsel learned of the judgment, or sixty (60) days after learning that the Motion for Reconsideration had been denied for having been filed out of time. Neither circumstance was met by petitioner. Subsequently, the MTC likewise denied a Motion for Reconsideration filed by petitioner. [9] Second, petitioner filed on 26 June 2000 a petition for certiorari [10] under Rule 65 with the Regional Trial Court (RTC) of La Trinidad, Benguet, imputing grave abuse of discretion to the MTC, and seeking to annul four (4) of the MTCs rulings, namely: the original 1998 judgment against petitioner; the 1999 order which declared that the Notice of Appeal was filed out of time; and the two orders dismissing the Petition for Relief from Judgment. The petition for certiorari was dismissed by the RTC in an Order [11] dated 21 November 2000. The RTC agreed with the MTC that the Petition for Relief from Judgment had been belatedly filed. The RTC also reiterated the consistent ruling that the judgment in question had already become final in February of 1998. Thus, the RTC could not ascribe grave abuse of discretion to the MTC. [12] Petitioner filed a motion for reconsideration of the RTC ruling, while respondent filed with the same court a motion for execution. On 3 July 2001, at a point when petitioner had allegedly not yet received any order acting on its motion for reconsideration, petitioner received instead an Order dated 21 June 2001 [13] where the RTC directed the issuance of a writ of execution in favor of respondent, the MTC judgment having already become final and