G.R. No. 213650 June 17, 2019
BOOKLIGHT, INC., Petitioner vs. RUDY O. TIU, Respondent

FACTS

Respondent Rudy O. Tiu filed a complaint for collection of sum of money against petitioner Booklight, Inc., his former lessee, for unpaid rentals from December 2001 after the lease contract expired. The Regional Trial Court (RTC) declared petitioner in default for failure to file a pre-trial brief and appear at pre-trial. This order of default, including the denial of petitioner’s motion to lift it, was subsequently upheld by the Court of Appeals and the Supreme Court. The RTC then proceeded with the ex parte presentation of respondent’s evidence and rendered a decision awarding various sums for unpaid rentals, attorney’s fees, litigation expenses, electric bills, and security services.
On appeal, the Court of Appeals (CA) affirmed the RTC decision but modified it by deleting the awards for legal interest on unpaid rentals, security services, litigation expenses, and attorney’s fees. Petitioner’s motion for partial reconsideration was denied. In this Petition for Review, petitioner now raises specific claims not addressed by the CA, including a demand for a refund of an alleged advance rental and deposit, the deletion of electric bill charges, and the application of proceeds from previously attached and garnished properties to satisfy the judgment.

ISSUE

Whether the Supreme Court can review the petitioner’s factual claims regarding the refund of advance rental, liability for electric bills, and the application of garnished funds to the judgment debt.

RULING

The Supreme Court denied the petition. The Court emphasized that a petition for review under Rule 45 is limited to questions of law. The issues raised by petitioner—specifically, the existence and refund status of an advance rental deposit, the period covered by the electric bill charges, and the exact value and application of proceeds from garnished properties—are inherently factual. Their resolution requires a re-examination and evaluation of the evidence on record, a function outside the scope of Rule 45 and typically reserved for the trial court as the trier of facts. The Court found no exceptional circumstances warranting a departure from this rule.
Furthermore, the Court clarified that the proper satisfaction of a monetary judgment is a matter for execution proceedings before the trial court. The petitioner’s claims regarding the set-off or deduction of its alleged credits from the judgment award, as well as the release of any excess from the garnished funds, must be properly raised and litigated in a motion for execution before the RTC. The Supreme Court does not function as a forum for the initial determination or execution of such claims. Thus, the assailed CA decision and resolution were affirmed.