http://sc.judiciary.gov.ph/jurisprudence/2009/march2009/150334.

htm

G.R. No. L-17712

As to the second point, jurisprudence on the matter has established that —

Whether an appeal by one of several judgment debtors will affect the liability of those who
did not appeal, must depend upon the facts in each particular case. If the judgment can only
be sustained upon the liability of the one who appeals, and the liability of the other judgment
debtors solely depends upon the question whether or not the appellant is liable, and the
judgment is revoked as to that appellant, then the result of his appeal will inure to the benefit
of all. Where the liability of each judgment debtor is several, and one appeals only, the
judgment on appeal will not affect those who did not appeal. (Municipality of Orion v.
Concha, 50 Phil. 679)

Petitioners herein are sued for the collection of a sum of money and upon the basis of a contract of
usufruct supposed to have been entered into between their co-defendants and the plaintiffs. As
already stated, the defense set up is that there was no annotation of any such usufruct on the title
issued in their names and that they were purchasers for value and in good faith of the property under
litigation. The right of any of the defendants to retain the property would depend upon the holding of
the appellate court on the tenability of such defense raised by them. In other words, the defense is
not personal to any or some of the defendants — it would apply to all. As the ruling is reiterated, "if
the judgment can only be sustained upon the liability of the one who appeals and the liability of the
other judgment debtors solely depends upon the question whether or not the appellant is liable and
the judgment is revoked as to that appellant, then the result of his appeal will inure to the benefit of
all." Exactly the same situation as described in this quotation is found to be obtaining in our case
and, therefore, We feel that execution on the holding as to the usufruct, pending appeal by some of
the defendants, should not issue against the other defendants who did not appeal (petitioners
herein).

G.R. Nos. 209415-17 (Lim-Bungcaras v. Commission on Elections, G.R. Nos. 209415-17 &
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210002, [November 15, 2016])

Finally, we address the effect of this Decision on the parties who failed to
perfect their appeal from the RTC judgment. In First Leverage and Services Group, Inc.
v. Solid Builders, Inc., 52 we had the occasion to state that:
This Court has always recognized the general rule that in appellate
proceedings, the reversal of the judgment on appeal is binding only on the
parties in the appealed case and does not affect or inure to the benefit of
those who did not join or were not made parties to the appeal. An exception
to the rule exists, however, where a judgment cannot be reversed as to the
party appealing without affecting the rights of his co-debtor, or where the
rights and liabilities of the parties are so interwoven and dependent on each
other as to be inseparable, in which case a reversal as to one operates as a
 reversal as to all. This exception, which is based on a communality of interest
of said parties, is recognized in this jurisdiction. . . . . (Citations omitted.)
To illustrate, in Unsay v. Palma, 53 we allowed the appeal of one defendant to
benefit his non-appealing co-defendants where the defense upon which the reversal
of the trial court's judgment was based was not personal to any or some of the
defendants but applied to all.
Persuasively, in American jurisprudence, the exception to the general rule on
non-appealing parties is stated, thus:
Where the judgment is entire and jointly binding on or in favor of
several coparties, or the cause of action is of such a nature that the rights and
issues are interdependent and injustice might result from a reversal as to less
than all the parties, the appellate court will reverse the judgment as to all. 54
Considering our determination that the trial court's award of moral damages
and attorney's fees in these consolidated election cases had no justification in fact or
law and this ground for reversal applies to all the petitioners, it would be grossly
unjust to limit our ruling only to those who perfected their appeals.
(Lim-Bungcaras v. Commission on Elections, G.R. Nos. 209415-17 & 210002, [November
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15, 2016])