Republic v. Court of Appeals
REITERATIONFacts
The Antecedents: The Republic of the Philippines, as lessor, owned a parcel of land leased to spouses Mercy de Vera and Juan A. de Vera for 25 years commencing January 1, 1952, renewable at the lessor's option. The Republic filed a complaint for unpaid rentals and termination of the lease. The trial court rendered judgment ordering the lessees to pay back rentals and a quarterly sum, with a declaration that the lease would be terminated and possession surrendered if payment was not made within three months. Procedural History: The lessees appealed to the Court of Appeals, which affirmed the trial court's decision. The decision became final and executory on August 27, 1968. The Republic filed a motion for execution, which was granted. However, the lessees filed a motion to recall the writ, questioning the validity of service of the decision and the entry of judgment. The Court of Appeals upheld the service, and this Court dismissed the lessees' subsequent petition for certiorari, mandamus, and prohibition. The Republic then filed a motion for an alias writ of execution, which the trial court granted. The lessees' motion for reconsideration and/or quashal was denied. The Court of Appeals, however, annulled and set aside the trial court's orders, directing the judge to admit evidence of new facts and circumstances and grant relief accordingly, without prejudice to the lessees' right to renew the lease. The Petition: The Republic filed a petition for review on certiorari, seeking to annul the Court of Appeals' decision and its resolution denying reconsideration, arguing that the trial court's decision could still be executed by motion and that the Court of Appeals erred in ruling on the renewal of the lease.
Issue(s)
Whether the decision of the trial court can be executed by mere motion. Whether the said decision can be executed at all. Whether the respondent court can rule on the renewal of the lease contract.
Ruling
The petition is GRANTED. The assailed decision and resolution of the respondent Court of Appeals are annulled and set aside. The Orders of the lower court dated July 12, 1974, November 8, 1974, and December 9, 1974, are affirmed. Treble costs are imposed upon the respondents De Veras, solidarily with their counsel, due to dilatory tactics.
Ratio Decidendi
On whether the decision can be executed by mere motion: The Court held that under Section 6 of Rule 39 of the Revised Rules of Court, a judgment may be executed on motion within five years from its entry or finality. The prescriptive period for enforcement by ordinary action is 10 years. In this case, the judgment became final on August 27, 1968. The Republic filed a motion for execution on April 15, 1969, well within the five-year period. Although the writ was recalled due to the lessees' actions, the time during which execution was stayed by their dilatory tactics should not be included in the computation of the five-year period. The filing of the motion for an alias writ of execution on January 25, 1974, after the dismissal of the lessees' petition by the Supreme Court on July 12, 1973, was seasonable and within the five-year period. The statute of limitations is intended for those who sleep on their rights, not for those prevented from acting by causes beyond their control. On whether the decision can be executed at all: The Court found that the lessees failed to pay the back rentals of P25,486.65 within the three-month period stipulated in the decision, which expired on November 25, 1968. Their attempt to pay on March 4, 1969, with a cashier's check, was significantly beyond the grace period. The Solicitor General's letter indicated that the payment was accepted as a settlement of an outstanding obligation, not as compliance with the court's decree, and that the lease was deemed terminated due to late payment. Therefore, the lease agreement was indeed terminated by operation of law due to the lessees' default, and the Republic was entitled to take possession of the leased property. On whether the respondent court can rule on the renewal of the lease contract: The Court ruled that the pronouncement by the Court of Appeals regarding the lessees' right to renew the lease or be given preferential rights was bereft of legal basis. The contract of lease explicitly stated that renewal was at the option of the lessor. The Republic, as the lessor, had no intention of renewing the contract due to the lessees' bad faith, failure to pay rentals, and subleasing the premises without authority. The lease had also expired on January 1, 1977, and the lessees' accumulated obligation had reached a substantial amount.
Main Doctrine
The period for executing a judgment by motion is tolled by delays occasioned by the debtor's actions, including appeals and petitions that effectively stay execution, thus preserving the creditor's right to seek execution within the five-year period from finality.