Samson v. Montejo
REITERATIONFacts
The Antecedents: Respondent Dionisio Dinglasa was the registered owner of a seven-hectare property acquired under the Homestead Law. On December 13, 1947, while incarcerated, he sold the property to petitioner Severino Samson for P2,000.00. On December 22, 1950, within the five-year redemption period, Dinglasa sought to repurchase the property, but Samson refused. Dinglasa filed an action for Redemption with Damages. Procedural History: The lower court, after Samson manifested no defense but asked for reimbursement of improvements, and subsequently failed to appear, authorized the Deputy Clerk of Court to receive evidence. Plaintiff proved the land's productivity (coconuts yielding not less than 4,000 nuts quarterly, valued at P150.00) and that Samson gathered and sold coconuts worth at least P3,300.00 from the time Dinglasa expressed his desire to repurchase. The court ordered Samson to execute a deed of resale, to reimburse P1,300.00 (compensating the P2,000.00 consideration with income enjoyed by Samson for 5 years and 8 months), and to pay P500.00 for attorney's fees and costs. This judgment was affirmed on certiorari (L-13203). A petition for Relief from Judgment was dismissed, and its dismissal was affirmed on appeal (L-15326). The Petition: On April 17, 1961, Samson filed a Motion to Modify Writ of Execution, alleging Dinglasa had been in possession and enjoyed the fruits during the pendency of proceedings. The respondent Judge, on April 27, 1961, ordered the amendment of the writ of execution to include P3,000.00 representing income enjoyed by Samson from the date of the decision to the date of the writ, increasing the total sum to P4,843.20. Samson filed the instant petition for Certiorari, alleging grave abuse of discretion and excess of jurisdiction, arguing that a final judgment cannot be modified.
Issue(s)
Whether the respondent Judge may lawfully order the modification of a writ of execution after the judgment has become final and executory. Whether Samson, having remained in possession and enjoyed the fruits of the property after the rendition of the decision, is ipso facto answerable to Dinglasa for the value of said fruits without further proceedings.
Ruling
The Court granted the petition, declaring the Order complained of (modification of the writ of execution) without force and effect. The writ of certiorari was granted, with costs against respondent Dionisio Dinglasa.
Ratio Decidendi
On the issue of modifying a final judgment: The Court held that once a decision becomes final, even the court which rendered it cannot lawfully alter or modify the same. This is especially true when the alteration or modification is material and substantial, as in this case where the liability of the petitioner was greatly augmented. The Court cited Rili, et al. v. Chunaco, et al. and Ablaza v. Sycip, et al. to support the principle that a final judgment is immutable. The mission of the court is limited to the execution and enforcement of the final judgment in all of its parts and in accordance with its express orders, as held in Behn, Meyer & Co. v. J. Mcking, et al.. To allow modification would be to disregard the finality of judgments and the established rules of procedure. On Samson's liability for fruits after the decision: The Court ruled that the circumstance that petitioner Samson remained in possession of the premises and enjoyed the fruits thereof does not ipso facto make him answerable to respondent Dinglasa for the value of said fruits after the rendition of the decision. Such claims require a separate proceeding where the parties can prove their respective claims. Samson might have valid defenses, such as entitlement to a share in the produce due to his labor, or that the land did not produce or had reduced production. These are matters that necessitate evidence and cannot be unilaterally imposed through a modification of an existing writ of execution.
Main Doctrine
A court cannot lawfully alter or modify a final and executory judgment, especially when such alteration is material and substantial, as it would augment the liability of a party without the benefit of a proper proceeding.