Spouses Buan v. Spouses La Torre
REITERATIONFacts
The Antecedents: Private respondents, Spouses La Torre, obtained a favorable decision in a sum of money case against G.L. Mejia Enterprises, Inc. for P16,729.00 plus legal interest and P4,000.00 attorney's fees. To enforce the award, two parcels of land titled in the name of G.L. Mejia Enterprises, Inc. (covered by TCT Nos. 21846 and 21882) were levied upon. TCT No. 21846 was sold to the La Torre spouses for P33,958.54. A notice of levy was inscribed on TCT No. 21882. Procedural History: Prior to the levy, on July 15, 1977, the parcel of land covered by TCT No. 21882 was the subject of a deed of assignment to petitioners, Spouses Buan, who assumed the obligation to pay for it by installments. The Buan spouses completed payment by January 15, 1982, and a deed of absolute sale was executed in their favor. However, they discovered the notice of levy on TCT No. 21882. The title was cancelled and a new one, TCT No. 60152, was issued to the Buan spouses, but the annotation was carried over. The Buan spouses filed actions for cancellation of notice of levy and quieting of title, which the RTC ruled in their favor. On appeal, the Court of Appeals (CA) reversed the RTC, ordering the cancellation of TCT No. 60152 and the issuance of a new title to the La Torre spouses. Appeals by the Buan spouses to the Supreme Court were denied. The CA decision became final and executory. The La Torre spouses moved for execution, and a writ was issued. Meanwhile, the Buan spouses filed a separate case for damages with preliminary injunction against G.L. Mejia Enterprises, Inc. and the Register of Deeds, and the RTC of Angeles City, Branch 56, issued an order granting a preliminary injunction, enjoining the cancellation of TCT No. 60152. The writ of execution was returned unsatisfied. The RTC of Branch 56 later made the injunction permanent and awarded damages. The La Torre spouses filed a petition for mandamus with the CA to compel the cancellation of TCT No. 60152. The CA granted the mandamus, setting aside the order of Branch 56 for having been issued with grave abuse of discretion, amounting to lack of jurisdiction, for interfering with a court of coordinate jurisdiction. The Petition: The Buan spouses appealed the CA's decision, arguing that the CA erred in disregarding facts and laws, in setting aside the order of Judge Rustia, and in disregarding its own internal rules. They contended that the judgment award in favor of the La Torre spouses had already been fully satisfied by the sale of the first parcel of land (TCT No. 21846), rendering the levy on the second parcel (TCT No. 60152) void due to overpayment.
Issue(s)
Whether the levy and attempted execution on TCT No. 60152 are valid despite the alleged full satisfaction of the judgment award through the sale of TCT No. 21846. Whether the Court of Appeals erred in setting aside the order of preliminary injunction issued by a court of coordinate jurisdiction.
Ruling
The appealed decision of the Court of Appeals is SET ASIDE. The order of the trial court ordering the cancellation of the annotation of the notice of levy on Transfer Certificate of Title No. 60152 is REINSTATED. Costs against private respondents.
Ratio Decidendi
On the validity of the levy and execution on TCT No. 60152: The Supreme Court ruled that the levy and attempted execution on TCT No. 60152 were void for being in excess of the original judgment award. The Court found that the judgment award in favor of the La Torre spouses amounted to P20,729.00 plus interest. The first parcel of land, covered by TCT No. 21846, was sold at auction for P33,958.54, which mathematically satisfied the judgment in full. Therefore, the notice of levy on the second parcel of land (TCT No. 60152) should have been canceled. The Court emphasized that a writ of execution must conform to the dispositive portion of the decision and that where a writ of execution is not in harmony with and exceeds the judgment, it has pro tanto no validity. Allowing the La Torre spouses to take the property covered by TCT No. 60152 on the basis of an excessive levy would result in unjust enrichment at the expense of the Buan spouses. The fact that the La Torre spouses sold the property they bought at auction for P280,000.00 is beside the point; what matters is that the judicial award of P20,729.00 had already been fully satisfied. On the interference with a coordinate court: While the Court of Appeals correctly ruled that a trial court has no power to interfere by injunction with the orders or judgments issued by another court of concurrent or coordinate jurisdiction, and thus Branch 56 of the RTC of Angeles City had no authority to enjoin the execution order issued by Branch 58, this procedural point was rendered moot by the substantive resolution of the first issue. The Court noted that the CA's decision setting aside the preliminary injunction likely intended to include the permanent injunction issued by Branch 56, as logic dictates that the reversal of the preliminary injunction would render the permanent injunction moot. However, the core issue of the validity of the levy on TCT No. 60152, which was the subject of the injunction, was resolved on its merits, rendering the procedural question of interference secondary.
Main Doctrine
A writ of execution that exceeds the judgment award is void pro tanto. Levy and execution on a property after the judgment debt has been fully satisfied through the sale of another property are invalid.