G.R. No. 193945, June 22, 2015.
REMINGTON INDUSTRIAL SALES CORPORATION, Petitioner, vs. MARICALUM MINING CORPORATION, Respondent.

FACTS

On August 1, 1984, Remington Industrial Sales Corporation (Remington) filed a complaint for sum of money against Marinduque Mining and Industrial Corporation (MMIC). The complaint was later amended to implead several defendants, including Philippine National Bank (PNB), Development Bank of the Philippines (DBP), and Maricalum Mining Corporation (Maricalum), as transferees of MMIC’s foreclosed assets. On April 10, 1990, the Regional Trial Court (RTC) rendered a decision in favor of Remington, holding all defendants jointly and severally liable. All defendants appealed. The Court of Appeals (CA) affirmed the RTC decision on October 6, 1995. PNB and DBP separately appealed to the Supreme Court. Maricalum’s motion for extension to file a petition was denied, making the CA decision final and executory as to it. The RTC granted Remington’s motion for execution against Maricalum, and garnished amounts from Maricalum’s bank deposits. Subsequently, the Supreme Court, in decisions dated August 16, 2001 (DBP case) and October 12, 2001 (PNB case), granted the petitions of DBP and PNB, reversing the CA decision and dismissing the complaint against them. Maricalum filed a petition (G.R. No. 158332) assailing the execution orders. On February 11, 2008, the Supreme Court granted Maricalum’s petition and annulled the RTC orders granting execution. After this decision became final, Maricalum filed a motion for restitution before the RTC for the garnished amounts. The RTC denied the motion, invoking the principle of immutability of final judgment, stating the execution was based on a valid order when the judgment was final against Maricalum. Maricalum filed a petition for certiorari with the CA. The CA granted the petition, annulled the RTC orders, and ordered Remington to return and restitute the garnished amounts with interest. Remington filed the present petition.

ISSUE

Whether the Court of Appeals erred in ordering Remington to return and restitute to Maricalum the garnished amounts, despite the prior finality of the judgment against Maricalum and the subsequent execution.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision with MODIFICATION on the interest rate. The Court held that restitution is warranted. The Supreme Court’s decision in G.R. No. 158332 (Maricalum case) annulling the execution orders had become final. This annulment carried with it the right to restitution of what had been paid under the annulled writ. The principle of immutability of final judgments admits of exceptions, such as when facts and events transpire that render its execution unjust and inequitable. The Supreme Court’s subsequent decisions in the DBP and PNB cases, which dismissed the complaint against the solidary debtors, constituted such a supervening event. Since the obligation was solidary, the dismissal of the complaint against PNB and DBP inured to the benefit of Maricalum, effectively releasing it from liability. It would be unjust to allow Remington to retain the amounts garnished from Maricalum after the very basis for its claim against the solidary debtors was extinguished. The Court modified the interest rate: twelve percent (12%) per annum from the filing of the motion for restitution (August 4, 2008) until June 30, 2013, and six percent (6%) per annum thereafter until full satisfaction.