Esquivel v. Alegre
REITERATIONFacts
The Antecedents: Petitioners Cresenciana Atun and Lamberto Esquivel were ordered to vacate a parcel of land in an ejectment case (Civil Case No. 990) in favor of respondents Teotimo Alaurin and Visitacion Magno. The respondents claimed prior possession, and alleged that petitioners' title was secured through fraud. This decision became final and executory. Procedural History: Before the ejectment judgment could be executed, petitioners filed a new case (Civil Case No. 4883) for reconveyance with nullity of judgment, damages, and preliminary injunction. A writ of preliminary injunction was issued, leading to a petition for certiorari by respondents (G.R. No. L-38826). The parties agreed to have Civil Case No. 4883 tried on the merits, with the winning party to possess the land. The trial court dismissed Civil Case No. 4883, dissolving the injunction. Petitioners appealed, but were ordered to amend their record on appeal. During this period, respondents sold the property to spouses Wilfredo Encinas and Patrocinia Dasmarinas. Petitioners filed a supplemental complaint impleading the new owners, who were declared successors-in-interest. The trial court's decision on the supplemental complaint was affirmed by the Court of Appeals and later by the Supreme Court (G.R. No. 74339). The original decision in Civil Case No. 4883 was also affirmed by the Court of Appeals and the Supreme Court. The original decision became final and executory on October 6, 1986. Petitioners took possession of the property on May 23, 1987, leading to a motion for contempt by respondents, which was dismissed. A restraining order was issued on June 8, 1987, directing petitioners to desist from occupying the premises. The Petition: Petitioners filed a motion praying for reconveyance of the property and cancellation of the new title, and for immediate possession, citing the agreement in the joint manifestation. The respondent judge denied this motion, and a subsequent motion for reconsideration was also denied. This led to the present petition for certiorari.
Issue(s)
Whether the decision rendered in the supplemental complaint modified the decision in the original complaint. Whether the respondent judge committed grave abuse of discretion in denying petitioners' motion for reconveyance and possession.
Ruling
The petition is DISMISSED for lack of merit. The restraining order issued by the respondent court on June 8, 1987 is made permanent.
Ratio Decidendi
On the issue of whether the supplemental decision modified the original decision: The Court held that the question must be answered in the negative. The original complaint for reconveyance stemmed from an ejectment case where the issue of prior possession was already decided in favor of the private respondents and had become res judicata. The supplemental complaint addressed the issue of successors-in-interest, specifically the Encinas spouses, who purchased the property from the original respondents. The supplemental decision declared the Encinas spouses as successors-in-interest, making them bound by the outcome of the appealed case. However, this declaration did not amend or revise the original decision on the merits of the reconveyance claim. The Court distinguished between an amended judgment and a supplemental judgment, stating that a supplemental decision merely bolsters or adds to the primary decision and exists side by side with the original, unlike an amended judgment which supersedes the original. In this case, the supplemental decision only declared the supplemental defendants as successors-in-interest and did not restudy the original decision's factual and legal issues. The prayer for reconveyance in the supplemental complaint was not justified in light of the original decision. The fact that petitioners pursued their appeal of the original decision indicated they did not believe the supplemental decision had amended the original. On the issue of grave abuse of discretion in denying the motion for reconveyance and possession: The Court found no grave abuse of discretion. The original decision in Civil Case No. 4883 had become final and executory on October 6, 1986. The prevailing party is entitled as a matter of right to a writ of execution, and its issuance is a ministerial duty. The writ of execution must conform to the judgment. In this case, the judgment to be executed was the original decision in Civil Case No. 4883. The restraining order issued on June 8, 1987, restored the status quo between the parties before May 23, 1987. The respondents, who were the prevailing parties, were already in actual possession of the property in accordance with the decision in Civil Case No. 4883 and paragraph 2 of the joint manifestation. Therefore, there was no need for the issuance of a writ of execution for petitioners to take possession. The respondent judge acted within his jurisdiction in denying the motion for reconveyance and possession, as it sought to alter a final and executory judgment and was contrary to the established status quo and the final decision.
Main Doctrine
A supplemental decision, unlike an amended judgment, does not supersede or extinguish the original decision but merely adds to or bolsters it. It cannot stand alone and only serves to incorporate new matters or developments that occurred after the original decision was rendered.