Spouses Davis v. Spouses Davis
REITERATIONFacts
The Antecedents: Spouses Larry and Flora Davis (petitioners) entered into a Contract to Sell with Spouses Florencio and Lucresia Davis (respondents) for a 500-square meter lot. Petitioners paid the full purchase price, but respondents failed to execute a Deed of Absolute Sale. Petitioners filed a Complaint for Specific Performance and Damages against respondents before the Regional Trial Court (RTC) of Malolos, Bulacan. The RTC ruled in favor of the petitioners, ordering respondents to execute the deed and pay damages. This decision was affirmed by the Court of Appeals (CA) and became final and executory. Procedural History: Following the finality of the RTC's decision, a writ of execution was issued but could not be implemented because respondents had already sold the subject property to third parties, who were issued a new title. Petitioners then filed an action for annulment of title and document against these new owners before another branch of the RTC. This action also resulted in a favorable ruling for the petitioners, declaring the new title void and restoring the original title in the respondents' names. Subsequently, petitioners filed an Urgent Ex-Parte Manifestation and Motion for the implementation of the original RTC decision. The RTC denied this motion, stating that the five-year period for execution by motion had lapsed and that the subsequent annulment action did not toll the period. The CA dismissed the petitioners' subsequent Petition for Certiorari on procedural grounds, specifically the failure to file a motion for reconsideration and the submission of incomplete documents. The Petition: Petitioners seek review of the CA's dismissal of their certiorari petition. They argue that the CA erred in dismissing their case on purely procedural grounds, contending that a motion for reconsideration of the RTC's denial was unnecessary because the RTC had already passed upon and resolved the core issue. Petitioners assert that the delay in executing the judgment was due to the respondents' actions (selling the property) and that the period during which they were compelled to file an action for annulment of title should be excluded from the five-year period for execution by motion. They invoke Rule 45 of the Rules of Court to bring their case before the Supreme Court, arguing that the CA committed grave abuse of discretion in dismissing their petition.
Issue(s)
Whether the Court of Appeals committed a reversible error in dismissing the Petition for Certiorari on purely procedural grounds. Whether the period for executing the February 13, 1998 RTC Decision by motion was tolled during the pendency of the action for annulment of title and document.
Ruling
The petition is GRANTED. The CA Resolutions dated May 22, 2017 and August 10, 2017, and the RTC Order dated February 7, 2017, are REVERSED and SET ASIDE. The Urgent Ex-Parte Manifestation and Motion filed by petitioners is GRANTED, and the RTC Malolos, Branch 78, is ordered to immediately issue a writ of execution to implement the February 13, 1998 Decision.
Ratio Decidendi
On the procedural issue of dismissing the Petition for Certiorari: The Supreme Court ruled that the CA committed a reversible error in dismissing the petition outright on the ground of failure to file a Motion for Reconsideration. While a Motion for Reconsideration is generally a sine qua non for a certiorari petition, it is not an ironclad rule. An exception exists where the issues raised in the certiorari proceeding have already been passed upon by the lower court. In this case, the RTC Malolos, Branch 78, had already ruled on the issue of whether the period for execution was tolled, making a motion for reconsideration before the RTC superfluous. Therefore, the CA's dismissal on this procedural ground was improper. On the issue of tolling the period for execution: The Supreme Court held that the period for executing the judgment by motion was indeed tolled. Under Section 6, Rule 39 of the Rules of Court, a judgment may be executed by motion within five years from its entry or finality. However, exceptions exist where the delay is caused by the judgment debtor or incurred for their benefit. In this case, the respondents deliberately sold the subject property to third parties, which necessitated the filing of an action for annulment of title by the petitioners. This delay was occasioned by the respondents' actions and was for their benefit, as it allowed them to evade the execution of the judgment. Therefore, the time spent litigating the annulment case should not be counted against the petitioners in computing the five-year period for execution by motion. To rule otherwise would reward the respondents for their evasion of their obligation.
Main Doctrine
The period for executing a judgment by motion is tolled when the delay in enforcement is caused by the actions of the judgment debtor, particularly when the debtor deliberately sells the property subject of the judgment, compelling the judgment creditor to file a separate action to protect their rights.