Macansantos v. Guinoo
REITERATIONFacts
The Antecedents: Bernabe Macansantos and Felisa Enriquez were married and had two sons, Lorenzo and Tomas. Bernabe acquired Lot No. 127-A. Felisa died in 1930. In 1934, Bernabe sold half of Lot No. 127 to Teofila de Guinoo, and in 1935, sold the other half to Honganji Mission. Both deeds were registered in 1940. Bernabe died in 1943. Procedural History: Lorenzo and Tomas Macansantos filed complaints seeking to declare the deeds of sale void, arguing the land was conjugal property and Bernabe had no authority to sell without their consent. The trial court dismissed the cases. The Court of Appeals affirmed dismissal against Honganji Mission but declared Teofila de Guinoo a purchaser in bad faith, ordering reconveyance of Lot 127-A to the heirs of Felisa Enriquez. This Court, in G.R. No. L-5541, modified the CA decision, ordering Teofila de Guinoo to reconvey only one-half of Lot 127-A to Lorenzo and Tomas Macansantos. The decision became final and executory. The Petition: When respondents refused to sign a deed of reconveyance, petitioners filed a motion for execution. Respondents proposed a deed of reconveyance with a P400.00 consideration and exclusion of improvements. Petitioners objected, arguing no consideration or exclusion of improvements was in the Supreme Court's decree. The trial court issued orders deemed by petitioners as gravely abusing discretion by substantially complying with the writ while allowing issues of consideration and improvements to be raised later, and refusing a writ of possession. Petitioners filed a petition for mandamus to compel the respondent judge to execute the decree without consideration or exclusion of improvements and to issue a writ of possession. Subsequently, petitioners filed Civil Case No. 2061 for partition and recovery of rentals and damages, raising similar issues. The trial court dismissed claims for damages and rentals and ownership of improvements, ordering partition.
Issue(s)
Whether the respondent Judge gravely abused his discretion in issuing orders that allegedly altered or modified the final decision of the Supreme Court regarding the reconveyance of Lot No. 127-A. Whether the issues concerning the consideration for the reconveyance, the inclusion of improvements, and the claim for rentals and damages are already barred by res judicata. Whether petitioners are entitled to a writ of possession for one-half of Lot No. 127-A, including improvements.
Ruling
The petition for mandamus is denied. The decision in Civil Case No. 2061 is affirmed. The claims of the plaintiffs (petitioners herein) with respect to damages and rentals, as well as the determination of the ownership of the improvements on the property, are dismissed. The defendants (respondents herein) are ordered to have the property partitioned between them and the plaintiffs.
Ratio Decidendi
On the alleged grave abuse of discretion and modification of the Supreme Court's decision: The Court reiterated that its decision in G.R. No. L-5541 was simple and plain, ordering Teofila de Guinoo to reconvey one-half of Lot No. 127-A without pronouncement as to improvements or consideration. The trial court correctly recognized that it could not change, amplify, enlarge, alter, or modify this final and executory decision. The insertion of a consideration or the exclusion of improvements in the deed of reconveyance would constitute such an alteration. The respondent Judge's orders, which allowed these issues to be raised separately or considered substantial compliance without altering the core reconveyance, were not considered grave abuse of discretion. On the issue of res judicata: The Court found that the issues raised in the mandamus proceedings and Civil Case No. 2061, specifically concerning improvements, consideration for reconveyance, rentals, and damages, were identical to those previously passed upon by this Court in G.R. No. L-5541 and in the mandamus case (G.R. No. L-13726). Since the decision in G.R. No. L-5541 had long become final and executory, these issues were deemed barred by res judicata. The filing of Civil Case No. 2061, which involved the same parties, subject matter, and issues, further solidified the application of res judicata and indicated that petitioners had other adequate remedies. On the entitlement to a writ of possession and determination of improvements/rentals: The Court affirmed the lower court's dismissal of claims for damages and rentals, as well as the determination of ownership of improvements. The original complaint in Civil Case No. 196 did not pray for adjudication of improvements, only for one-half of the lot and compensation for its use. The Supreme Court's decision in G.R. No. L-5541 did not include improvements. Therefore, the trial court correctly held that it was not in a position to issue a writ of possession before the parties were entitled to physical possession of their respective shares, and that the issues regarding improvements and rentals were already settled or barred by prior judgments.
Main Doctrine
A trial court cannot alter, amplify, enlarge, or modify a final and executory decision of an appellate court. Issues that have been previously ruled upon and decided by a final judgment are considered res judicata and cannot be relitigated.