GR 186063; (January, 2014) (Digest)
G.R. No. 186063 ; January 15, 2014
PHILIPPINE NATIONAL BANK, Petitioner, vs. SAN MIGUEL CORPORATION, Respondent.
FACTS
Respondent San Miguel Corporation (SMC) entered into an Exclusive Dealership Agreement with Rodolfo Goroza. To secure a credit line with SMC, Goroza obtained a letter of credit from petitioner Philippine National Bank (PNB). SMC later filed a collection case against both Goroza and PNB before the Regional Trial Court (RTC) for Goroza’s unpaid purchases. Goroza was declared in default, and the RTC proceeded to trial ex parte against him. On May 10, 2005, the RTC rendered a decision solely against Goroza, ordering him to pay SMC the principal amount, interest, attorney’s fees, and litigation expenses.
Goroza filed a notice of appeal, which the RTC gave due course. Meanwhile, the case against PNB continued. The RTC subsequently issued a Supplemental Judgment and an Amended Order clarifying that its decision against Goroza was “without prejudice” to the ongoing proceedings against PNB. PNB moved for reconsideration, arguing that the perfection of Goroza’s appeal divested the RTC of jurisdiction over the entire case, making the supplemental issuances void. The RTC denied the motion. The Court of Appeals affirmed the RTC, prompting PNB to elevate the case to the Supreme Court.
ISSUE
Whether the RTC retained jurisdiction to continue proceedings against PNB and to issue the Supplemental Judgment and Amended Order after Goroza perfected his appeal.
RULING
Yes. The Supreme Court denied PNB’s petition and affirmed the Court of Appeals. The perfection of Goroza’s appeal did not divest the RTC of jurisdiction to continue the trial and resolve the case against PNB. The ruling against Goroza was a separate and distinct judgment from the claims against PNB. The case involved multiple defendants, and a judgment against one does not necessarily constitute a complete adjudication of all issues regarding all parties, especially when their liabilities are alleged to be based on different legal grounds.
The Court emphasized that PNB’s potential liability stemmed from its obligations as the issuer of a letter of credit, which is governed by the principle of independence. This principle dictates that the letter of credit is separate from the underlying contract between SMC and Goroza. Therefore, a finding of liability against Goroza for the principal debt does not automatically absolve PNB of its independent contractual commitment under the letter of credit. The RTC correctly continued the proceedings to determine PNB’s separate liability, if any. The Supplemental Judgment and Amended Order were merely clarificatory and did not constitute a new judgment, thus they were within the RTC’s jurisdiction to issue.