PHILIPPINE NATIONAL BANK v. SAN MIGUEL CORPORATION

FACTS:

The petitioner, Philippine National Bank (PNB), and respondent San Miguel Corporation (SMC) entered into an Exclusive Dealership Agreement where SMC was granted the right to sell PNB's beer products. In order to apply for a credit line with PNB, SMC required a letter of credit. Goroza, a dealer of SMC, obtained a letter of credit and availed of his credit line to sell SMC's beer products. However, Goroza became delinquent in paying his accounts.

SMC filed a Complaint for collection of sum of money against PNB and Goroza. Goroza was declared in default, and the trial proceeded against him. The Regional Trial Court (RTC) ruled in favor of SMC, ordering Goroza to pay the principal amount, interest, attorney's fees, and litigation expenses. Goroza filed a Notice of Appeal, while SMC filed a Motion for Reconsideration. The RTC granted SMC's motion and increased the award for litigation expenses.

The RTC issued an order giving due course to Goroza's Notice of Appeal and required the reproduction of the records for forwarding to the Court of Appeals. PNB filed an Urgent Motion to Terminate Proceedings, but the RTC denied it. The RTC issued a Supplemental Judgment and Amended Order, clarifying that the decision rendered against Goroza was without prejudice to the decision to be made against PNB. PNB filed a Motion for Reconsideration, but the RTC denied it.

PNB then filed a special civil action for certiorari with the Court of Appeals (CA) as it disagreed with the RTC's resolution. The CA denied the petition and affirmed the RTC's decision. PNB filed a Motion for Reconsideration, but the CA also denied it. Subsequently, PNB filed a petition for review on certiorari with the Supreme Court.

ISSUES:

  1. Whether the trial court was correct in rendering a supplemental judgment and amended order against the bank despite the perfection of appeal of one of the defendants.

RULING:

  1. The Court of Appeals did not err in holding that the trial court was correct in rendering a supplemental judgment and amended order against the bank despite the perfection of appeal of one of the defendants.

PRINCIPLES: