Spouses Lazaga v. Aguinaldo
REITERATIONFacts
The Antecedents: Atlas Consolidated Mining and Development Corporation (Atlas) filed an eminent domain case against Spouses Ananias and Ignacia Lazaga (Spouses Lazaga) for power transmission lines. The CFI ordered Spouses Lazaga to allow Atlas possession upon deposit of P5,041.50. Later, Spouses Lazaga executed agreements for power transmission right of way over specific areas and a deed of absolute release and quit-claim for P20,459.00 as final payment for damages. A dispute arose regarding the actual area occupied by Atlas, with Spouses Lazaga claiming it exceeded the agreed-upon portions. Procedural History: Spouses Lazaga filed a forcible entry and unlawful detainer case against Atlas. The City Court ruled in favor of Spouses Lazaga, finding Atlas guilty of forcible entry and unlawful detainer over 743 sq. meters, ordering return of possession and payment of damages and attorney's fees. Atlas appealed to the CFI, which affirmed the City Court's decision but increased damages and attorney's fees. Atlas then filed a petition for review with the Court of Appeals (CA). The CA affirmed the findings of fact regarding the 743 sq. meter gap but modified the monetary awards, remanding the case to the City Court to determine reasonable rental or value of use and occupancy, and reducing damages and attorney's fees. Atlas's petition for review to the Supreme Court was denied. The CA decision was remanded to the City Court. After failed settlement attempts, the City Court, on April 8, 1976, resolved that P5.00 per square meter for an outright sale of the 743 sq. meters would be the just and reasonable value. Spouses Lazaga did not appeal this resolution. Subsequently, Atlas filed a motion for satisfaction of judgment with the CFI, depositing P3,715.00. The CFI ordered Spouses Lazaga to execute a public document acknowledging satisfaction and a Deed of Sale. Spouses Lazaga's motion for reconsideration was denied. They then filed a motion for alias writ of execution, which the CFI denied as moot and academic. The Petition: Spouses Lazaga filed a petition for certiorari seeking to nullify the CFI's order denying their motion for alias writ of execution, arguing that the CA decision mandated the City Court to receive evidence on rental value, not to require an outright sale, and that the P3,715.00 should be considered monthly rental.
Issue(s)
Whether the City Court of Toledo exceeded the mandate of the Court of Appeals' decision by resolving the issue of outright sale instead of receiving evidence on rental value. Whether the denial of the motion for alias writ of execution was proper.
Ruling
The petition is dismissed for lack of merit. The denial of the motion for alias writ of execution was proper as it was moot and academic. The City Court of Toledo did not exceed its mandate, and its resolution regarding the outright sale was reasonable and not appealed by the petitioners, thus becoming final and executory.
Ratio Decidendi
On the City Court's mandate and resolution: The Court of Appeals' decision remanded the case to the City Court to explore amicable settlement and, failing that, to "receive evidence on the reasonable rental or value of the use and occupancy of the same and to render a decision on the basis thereof." The City Court did attempt amicable settlement, which failed. Subsequently, it required parties to submit memoranda and then resolved, as an alternative, the payment of P5.00 per square meter for an outright sale of the 743 square meters. This resolution was not appealed by the petitioners, making it final and executory. The Court found that the City Court's action was a reasonable alternative to resolving the dispute, especially given the parties' inability to agree on a settlement or rental value. The petitioners' argument that the P3,715.00 should be considered monthly rental was deemed "bloated beyond reason," while Atlas's proposed P1.00 per square meter was considered too low. The P5.00 per square meter price was deemed reasonable, considering Spouses Lazaga had accepted P20,459.00 for a much larger area of similar land. On the denial of the alias writ of execution: The motion for alias writ of execution was filed after the City Court's resolution of April 8, 1976, had become final and executory, and after Atlas had deposited the corresponding payment. The Court of First Instance had previously suspended an earlier writ of execution precisely because the case was remanded to the City Court for further proceedings. Therefore, the subsequent motion for an alias writ of execution, seeking to enforce a judgment that had been superseded by a final and executory resolution of the City Court, was indeed moot and academic. The petitioners' failure to appeal the City Court's resolution of April 8, 1976, rendered it final and binding.
Main Doctrine
A motion for alias writ of execution is moot and academic when the underlying judgment has become final and executory, and subsequent proceedings have already resolved the matter, especially when the original motion was denied for being premature or based on a misunderstanding of the appellate court's mandate.