Ver v. Quetulio
REITERATIONFacts
1. The Antecedents: This case originates from a complaint filed by Primo Quetulio seeking to quiet title to sixteen parcels of land. Quetulio claimed ownership based on a deed of sale from Mercedes Ver, who allegedly acquired the properties through inheritance and donation from her brother, Fr. Ramon Ver. The defendants and intervenors, who were heirs and collateral relatives of the Ver family, contested Quetulio's claim. They asserted that the properties were part of the undivided estate of their ancestor, D. Leon Ver, and that Mercedes Ver and Fr. Ramon Ver had only administered these common properties. They argued that Mercedes Ver could not validly sell these co-owned properties without the consent of all co-heirs. 2. Procedural History: The Court of First Instance initially ruled in favor of the defendants and intervenors, declaring the deed of sale void and the properties as common and undivided, except for one parcel. Quetulio appealed to the Supreme Court (G.R. No. L-6831), which modified the decision, declaring Quetulio as the owner of the undivided share of the heirs of Juan Ver in parcels 67 and 68, and remanding the case for further proceedings. Subsequent attempts to execute this decision led to further litigation, including G.R. No. L-16406, where the Supreme Court clarified that the decision was not yet final and executory due to pending partition and accounting. The case then went through various lower court and appellate court proceedings, including CA-G.R. No. 52744-R and AC-G.R. CV No. 00206, with conflicting interpretations of the Supreme Court's earlier rulings regarding Quetulio's interest in parcels 67 and 68. A modified decision by the Intermediate Appellate Court in AC-G.R. CV No. 00206, declaring Quetulio the owner of the whole of lots 67 and 68, was later dismissed on review by the Supreme Court (G.R. No. 72958), which reiterated that Quetulio's interest was limited to the undivided share of Juan Ver's heirs. 3. The Petition: The petitioners, represented by Vicente Ver and others, seek a writ of certiorari to set aside orders from the Regional Trial Court of Ilocos Norte dated January 21, 1987, and February 12, 1987. These orders directed the execution of a decision by the Intermediate Appellate Court which the petitioners argue is void and contrary to the final decisions of the Supreme Court, particularly G.R. No. L-6831. The petitioners contend that the Supreme Court's resolution in G.R. No. L-6831 definitively established that Primo Quetulio's interest in lots 67 and 68 was limited to the undivided share of the heirs of Juan Ver, and that the Intermediate Appellate Court exceeded its jurisdiction by declaring Quetulio the owner of the entire lots. They also challenge the legality of the writ of execution and subsequent orders, including an auction sale of intervenors' properties, which they assert were based on a void judgment.
Issue(s)
Whether the Intermediate Appellate Court's modified decision was correct in declaring Primo Quetulio as the owner of the whole of lots 67 and 68, contrary to the Supreme Court's final decision in G.R. No. L-6831. Whether the Intermediate Appellate Court was correct in awarding damages in favor of Primo Quetulio. Whether the heirs of the deceased defendants are liable for said damages. Whether the writ of execution and subsequent orders of the Regional Trial Court were issued legally.
Ruling
The petition is granted. The questioned orders of the Regional Trial Court are set aside. The case is remanded for appropriate proceedings in accordance with the Supreme Court's decision in G.R. No. L-6831. A permanent injunction is issued against the provincial sheriff from executing a final deed of sale in favor of Dominica Q. Hernando based on the January 14, 1987 auction sale.
Ratio Decidendi
On the issue of the Intermediate Appellate Court's modified decision contradicting the Supreme Court's final judgment: The Supreme Court held that the Intermediate Appellate Court erred in interpreting and modifying the Supreme Court's final judgment in G.R. No. L-6831. The Court reiterated that its resolution dated November 6, 1956, in G.R. No. 6831, unequivocally declared that Quetulio's interest in lots 67 and 68 was limited to the undivided share of the heirs of Juan Ver. The Supreme Court emphasized that a lower court has only a ministerial function to execute a higher court's judgment and is devoid of supervisory jurisdiction to interpret or reverse it. The Court cited Ang Ping and Carmen Pimentel v. Regional Trial Court of Manila and Tugade v. Court of Appeals to underscore that the Supreme Court speaks with finality, and its pronouncements are binding on lower courts. The dismissal of the petition in G.R. No. 72958 did not alter the finality of the 1956 decision regarding the extent of Quetulio's interest. On the issue of the award of damages: The Supreme Court noted that the decision in G.R. No. L-6831 affirmed the lower court's award of damages but stipulated that the value of fruits from Quetulio's undivided interest should be deducted. The Court found that the accounting report by Apolinar Quetulio, which formed the basis for the P55,038.20 damages awarded by the Court of Appeals, was set aside in a prior appellate decision (CA-G.R. No. 52744-R) that had become final. Therefore, it was an error for the appellate court to adopt this set-aside accounting. On the issue of the liability of heirs for damages: While not explicitly addressed as a separate issue, the Court's ruling on the impropriety of the damages awarded by the appellate court implicitly affects the liability of the heirs. The underlying judgment for damages was found to be based on an erroneous interpretation of the Supreme Court's decision and an invalidated accounting report. On the legality of the writ of execution and subsequent orders: The Supreme Court ruled that the lower court erred in issuing the writ of execution based on the questioned decision of the Intermediate Appellate Court, which was deemed null and void for contradicting the Supreme Court's final judgment. Consequently, the auction sale conducted by the sheriff to satisfy this void judgment was also declared null and void. The Court permanently enjoined the sheriff from executing a final deed of sale in favor of Dominica Q. Hernando.
Main Doctrine
A lower court is without supervisory jurisdiction to interpret or to reverse the judgment of a higher court; its function is ministerial, limited to issuing the order of execution.