G.R. No. L-32550 October 27, 1983
PHILIPPINE VIRGINIA TOBACCO ADMINISTRATION, petitioner, vs. HON. ANTONIO G. LUCERO, RAMON O. NOLASCO and ARSE SOLIDUM, as Associate Justices of the Court of Appeals; HON. WALFRIDO DE LOS ANGELES, as Judge of the Court of First Instance of Rizal; BATAC EASTERN BARRIOS VTPA, et al., and THE RIZAL COMMERCIAL BANKING CORPORATION, respondents.

FACTS

Multiple tobacco planters’ associations filed three separate civil cases against the Philippine Virginia Tobacco Administration (PVTA) and the Central Cooperative Exchange, Inc. (CCE) for unpaid tobacco shipments. The cases were jointly tried. During the proceedings, the trial court rendered several partial judgments in favor of some plaintiffs, which were executed despite appeals interposed by PVTA. On October 30, 1969, the respondent judge rendered another set of partial judgments. The following day, the winning plaintiffs filed an urgent motion for execution pending appeal, citing reasons including the incontrovertible nature of the facts, a statutory payment priority for their claims under RA 4155, the potential termination of a tobacco subsidy law causing irreparable injury, and PVTA’s own prior manifestations implying acknowledgment of the claims’ validity.
PVTA opposed the motion, arguing its appeal was meritorious, the plaintiffs had already collected substantial amounts from prior partial judgments, the alleged urgency was speculative, and previous executions did not automatically justify a new one. The trial court, in an order dated November 5, 1969, granted execution pending appeal, finding the plaintiffs’ reasons sufficient and compelling. It required the plaintiffs to post bonds, which they did. PVTA then filed a petition for certiorari with the Court of Appeals, seeking to annul the execution order. The appellate court dismissed the petition, prompting PVTA to elevate the case to the Supreme Court via appeal by certiorari.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari and in upholding the trial court’s order granting execution pending appeal.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic centers on the discretionary power of the trial court to grant execution pending appeal under Section 2, Rule 39 of the Rules of Court, which requires “good reasons” stated in a special order. The Court held that the trial judge did not gravely abuse his discretion. The reasons cited in the November 5, 1969 order—including the substantiated claims, the plaintiffs’ legal right to a statutory priority in payment, and the potential for irreparable injury—constituted valid “good reasons.” Furthermore, the requirement for the plaintiffs to post substantial bonds (totaling P647,500.00) provided an additional safeguard and is itself recognized as a special ground authorizing execution pending appeal.
Crucially, the Court emphasized that certiorari is an extraordinary remedy available only for correcting grave abuse of discretion amounting to lack or excess of jurisdiction. The petition failed to demonstrate that the trial court’s discretion was exercised arbitrarily or despotically. Moreover, PVTA had an adequate remedy at law which it failed to avail: it could have stayed the execution by filing a supersedeas bond as provided under Section 3, Rule 39. Having neglected this statutory remedy, PVTA was not entitled to the extraordinary writ of certiorari. The appellate court’s dismissal was therefore correct.