Macansantos v. Fernan
REITERATIONFacts
The Antecedents: Bernabe Macansantos and Feliza Enriquez were married and had two sons, Lorenzo and Tomas. Bernabe acquired a lot in Davao City, registered in his name married to Feliza. After Feliza's death, Bernabe sold one-half of the lot to Teofila de Guinoo and the other half to Honganji Mission. Both sales were registered, and new titles were issued to the buyers. Bernabe died in 1943. Procedural History: Petitioners Lorenzo and Tomas Macansantos filed complaints to declare the sales void, arguing the land was conjugal property and Bernabe could not sell it without their consent. The trial court dismissed the cases. The Court of Appeals affirmed the dismissal regarding the Honganji Mission sale but reversed the decision concerning Teofila de Guinoo, ordering her to reconvey Lot 127-A to the heirs of Feliza Enriquez, finding her a purchaser in bad faith. The Petition: Petitioners filed a petition for certiorari with the Supreme Court. The Supreme Court modified the Court of Appeals' decision, sentencing Teofila de Guinoo to reconvey only one-half of Lot 127-A to Lorenzo and Tomas Macansantos, and affirmed the judgment as modified. Upon the decision becoming final and executory, petitioners sought execution. The Guinoos refused to sign a deed of reconveyance, proposing a deed that included a P400.00 consideration and excluded improvements. The trial court issued an order stating the deed was substantial compliance and that claims for consideration and improvements could be raised later. Petitioners filed the present action for mandamus, alleging grave abuse of discretion by the respondent judge for not enforcing the Supreme Court's decision strictly.
Issue(s)
Whether the respondent Judge gravely abused his discretion in issuing orders that did not strictly enforce the Supreme Court's final and executory decision regarding the reconveyance of Lot 127-A. Whether the deed of reconveyance should include a monetary consideration and exclude improvements, contrary to the Supreme Court's judgment.
Ruling
The petition for mandamus is denied. The Court held that the orders of the respondent Judge, while potentially subject to appeal, were not subject to mandamus as petitioners had another adequate remedy by filing a separate civil case for partition and recovery of rentals, which they subsequently did. Furthermore, the Court found that the trial court correctly recognized its inability to alter the final judgment of the Supreme Court.
Ratio Decidendi
On Issue 1: The Court ruled that the petition for mandamus was not the proper remedy because the petitioners had an adequate remedy in the ordinary course of law. They had already filed Civil Case No. 2061 for partition and recovery of rentals, which involved the same issues as the mandamus proceedings. The Court noted that the orders of February 9, 1956, and April 18, 1956, were final orders on the merits of the issues raised therein and were therefore appealable, not subject to mandamus if an adequate remedy existed. The filing of Civil Case No. 2061 estopped the petitioners from claiming they had no other plain, speedy, and adequate remedy. On Issue 2: The Court emphasized that the Supreme Court's decision in G.R. No. L-5541 was clear and simple, ordering Teofila de Guinoo to reconvey one-half of Lot 127-A without mentioning any improvements or consideration. The trial court correctly understood that it could not alter, amplify, enlarge, or modify this final and executory decision. The insertion of a monetary consideration or the exclusion of improvements in the deed of reconveyance would constitute a modification of the Supreme Court's judgment, which the trial court has no power to do. Therefore, the respondent Judge's orders, which allowed these matters to be potentially resolved in separate proceedings, were not considered grave abuse of discretion in light of the available remedy in Civil Case No. 2061.
Main Doctrine
The Supreme Court reiterated that a trial court is bound by the final and executory decisions of the appellate court and cannot alter, amplify, enlarge, or modify them. In this case, the trial court's orders regarding the deed of reconveyance, which attempted to introduce considerations and exclusions not present in the original Supreme Court decision, were deemed to be an unlawful modification of the judgment. The Court emphasized that the execution of a judgment must strictly conform to its terms, and any deviation constitutes grave abuse of discretion.