Policarpio v. Regional Trial Court of Quezon City, Branch 83
REITERATIONFacts
The Antecedents: Petitioner Lumen Policarpio entered into a "Pre-need Purchase Agreement" with private respondent Group Developers and Financiers, Inc. for a memorial lot and a "Supplemental Agreement" for the construction of a "Family Court Unit." Petitioner paid the downpayments for both agreements but failed to remit the subsequent installments. Both agreements stipulated that failure to comply would allow the private respondent to declare the agreements null and void after thirty (30) days, retain all payments as liquidated damages, and re-enter the premises. Procedural History: Private respondent filed an action for rescission and damages. Petitioner was declared in default. The trial court rendered judgment for the plaintiff, rescinding the agreements, forfeiting the downpayments, and ordering the petitioner to pay for the interment unit or allow disinterment. Private respondent filed a motion for reconsideration, which was granted, amending the dispositive portion to order petitioner to pay the full balance or surrender the premises and pay damages. A second motion for reconsideration by private respondent further amended the order to include outstanding interest, attorney's fees, and costs. Both parties appealed. The Court of Appeals ruled in favor of petitioner. On appeal, this Court (G.R. No. 73421) set aside the Court of Appeals' decision and reinstated the dispositive portion of the trial court's decision dated July 8, 1974. Private respondent moved for execution, which the RTC granted. Petitioner sought reconsideration and filed a motion for clarification. The RTC deferred action pending this Court's resolution of the clarification motion, which was referred back to the trial court. Petitioner offered to pay P140,000.00, which was rejected. Private respondent moved to enforce execution. Petitioner filed a motion for consignation. The RTC issued the questioned order declaring that only the Decision dated July 8, 1974, without amendments, should be enforced by writ of execution, denying petitioner's motions and granting private respondent's motion to enforce execution. The Petition: Petitioner seeks to reverse the RTC's order, arguing that the RTC erred in not considering the subsequent orders of October 3, 1974, and December 30, 1974, in implementing the July 8, 1974 decision, and that private respondent is estopped from insisting on the implementation of the July 8, 1974 decision without considering these subsequent orders and the meaning imparted by the Supreme Court's decision.
Issue(s)
Whether the Regional Trial Court erred in enforcing only the July 8, 1974 decision and not considering the subsequent amendatory orders of October 3, 1974, and December 30, 1974. Whether the private respondent is estopped from insisting on the implementation of the July 8, 1974 decision without considering the subsequent orders and the Supreme Court's interpretation.
Ruling
The petition is dismissed, and the order dated September 14, 1992, of the Regional Trial Court is affirmed in toto.
Ratio Decidendi
On the issue of enforcing the July 8, 1974 decision: The Supreme Court reiterated that its decision dated November 29, 1988, had categorically stated that "the dispositive portion of the trial court's decision rendered on July 8, 1974 is . . . reinstated." The Court emphasized that once a decision has become final and executory, it is no longer open to amendments or modifications. To allow such modifications would lead to endless litigation. The Supreme Court's directive to reinstate the July 8, 1974 decision was specific and binding on the lower court. The Court clarified that its decision did not fail to take into account the subsequent orders of the trial court, but rather, it chose to reinstate the original judgment based on the pleadings and the applicable rules. The Court noted that nowhere in the petitioner's pleadings was her indebtedness denied, and her appeal primarily questioned being declared in default and the conversion of the suit to one for specific performance. The Court underscored the principle that a judgment by default cannot exceed the amount or be different in kind from that prayed for in the complaint, and its decision of November 29, 1988, accorded with the private respondent's prayer in its complaint. On the issue of estoppel: The Supreme Court held that it was too late in the day for the petitioner to raise the issue of estoppel. Such an issue should have been threshed out in the previous case (G.R. No. 73421) where the Supreme Court made its definitive ruling. The finality of judgments precludes the re-litigation of issues that were or could have been raised in the earlier proceedings. The principle of res judicata bars the reopening of matters already decided by a competent court. Therefore, the RTC correctly denied the petitioner's motions and proceeded with the execution of the reinstated decision.
Main Doctrine
A final and executory decision of the Supreme Court, having become the law of the case, cannot be modified or amended by the trial court, even if subsequent orders were issued by the trial court that appear to contradict the Supreme Court's reinstated decision.