Torres v. Sison
REITERATIONFacts
The Antecedents: This case originated from an action for rescission of the sale of two parcels of land filed by Emilio Olores against Ceferino and Araceli Illuscupides, and Vivencio and Socorro Torres. After trial, the Regional Trial Court dismissed the complaint for rescission and ordered the Illuscupides and/or Torres to deliver P41,000.00 withheld as part of the purchase price, along with attorney's fees and costs, to satisfy Olores' claim. The Illuscupides appealed to the Court of Appeals. Procedural History: The Court of Appeals affirmed the dismissal of Olores' complaint and the dismissal of cross-claims and counter-claims. However, it reversed the trial court's decision regarding the P41,000.00, attorney's fees, and costs, ordering the spouses Vivencio and Socorro Torres to reconvey a ten-door apartment building to the spouses Ceferino and Araceli Illuscupides. The Supreme Court, in G.R. No. 92248, denied the petition for review on certiorari filed by the Torreses, affirming the Court of Appeals' decision, which became final and executory on July 25, 1990. Subsequently, the Illuscupides filed a petition (G.R. No. 93390) seeking to modify the Court of Appeals decision to allow repurchase of the lots, not just the apartment. The Supreme Court affirmed the Court of Appeals decision in toto on December 9, 1992, which became final and executory on March 8, 1993. The Illuscupides then filed a motion for execution with the trial court based on the Supreme Court's resolution in G.R. No. 92248, ordering the reconveyance of the lots and apartment. The trial court granted this motion and issued a writ of execution. The petitioners filed a motion to quash the writ, which was denied. The Petition: This special civil action for certiorari seeks to annul the trial court's order finding the motion for execution meritorious and the order denying the motion to quash the writ of execution. The petitioners also seek clarification on which of two allegedly conflicting Supreme Court rulings shall prevail. They argue that the inclusion of the reconveyance of the lots in the Supreme Court's resolution in G.R. No. 92248 was a mere typographical error and not a departure from established jurisprudence. They further contend that the decision in G.R. No. 93390, which affirmed the Court of Appeals decision in toto, should prevail over the minute resolution in G.R. No. 92248, as it disposed of the rights concerning the lot. The core issue is whether the minute resolution in G.R. No. 92248 was superseded by the decision in G.R. No. 93390.
Issue(s)
Whether the phrase "ordering the petitioners to pay contractor's fee and to reconvey the lots and apartment building to respondents Illuscupides" in the resolution of G.R. No. 92248 was a mere paraphrase or a typographical error, particularly the inclusion of the reconveyance of the lot. Whether the order to reconvey the lot, if not a typographical error, was a departure from jurisprudence that no affirmative relief can be given to a party who did not appeal. Whether the order to reconvey the lot, not prayed for in the Torreses' petition, was inconsistent with the finding of no reversible error in the Court of Appeals' decision. Whether the order to reconvey the lots violated the constitutional requirement of due process. Whether the decision in G.R. No. 93390, which affirmed in toto the Court of Appeals decision, finally disposed of the rights of the Illuscupides as to the lot. Whether the decision in G.R. No. 93390 was a supervening event legally sufficient to prevent the enforcement of the minute resolution in G.R. No. 92248. If the minute resolution in G.R. No. 92248 granted affirmative relief, which ruling shall prevail: the minute resolution in G.R. No. 92248 or the decision in G.R. No. 93390.
Ruling
The petition is dismissed for lack of merit. The decision in G.R. No. 93390 did not alter or modify the resolution in G.R. No. 92248. A final and executory judgment of the Supreme Court cannot be altered or modified, except for clerical errors. An order of execution that varies the tenor of the judgment or exceeds the terms thereof is a nullity. The trial court properly granted the motion for a writ of execution based on the final and executory resolution in G.R. No. 92248.
Ratio Decidendi
On the issue of whether the phrase was a paraphrase or typographical error: The Court held that the decision in G.R. No. 93390 did not alter or modify the resolution in G.R. No. 92248. It emphasized the principle that a final and executory judgment of the Supreme Court cannot be altered or modified, except for clerical errors, misprisions, or omissions. The Court cited several cases, including Filcon Manufacturing Corp. v. NLRC, to support this principle. Therefore, the resolution in G.R. No. 92248, which had become final and executory, remained valid and enforceable. On the issue of whether the order to reconvey departed from jurisprudence: The Court reiterated that no inferior court has the authority to revoke a resolution of a superior court, especially a final and executory resolution of the Supreme Court. The Supreme Court itself has no power to revoke such a resolution after it has become final. Any amendment or alteration that substantially affects a final and executory judgment is considered null and void for lack of jurisdiction. This principle underscores the immutability of judgments once they attain finality. On the issue of whether the order to reconvey was inconsistent with the finding of no reversible error: The Court found that the trial court properly granted the respondents' motion for a writ of execution on July 14, 1994, based on the Supreme Court's resolution in G.R. No. 92248, which became final and executory on July 25, 1990. The execution was sought after the entry of judgment and before the decision became stale, in accordance with Rule 39, Section 6 of the Revised Rules of Court. Therefore, the writ of execution was a valid means to enforce the final judgment. On the issue of whether the order to reconvey violated due process: The Court clarified that an order of execution which varies the tenor of the judgment or exceeds the terms thereof is a nullity. This means that the execution process must strictly adhere to the dispositive portion of the final judgment. Any attempt to enforce terms not included in the judgment or to alter its meaning would render the execution order void. This protects the integrity of final judgments and prevents undue expansion of their scope. On the issue of whether G.R. No. 93390 finally disposed of the rights of the Illuscupides: The Court invoked the principle that all litigation must at last come to an end, however unjust the result of error may appear. This public policy is crucial for the stability of legal relations and the efficient administration of justice. On the issue of whether G.R. No. 93390 was a supervening event: Allowing endless challenges to final judgments would make litigation intolerable and undermine the judicial system's capacity to resolve disputes definitively. The principle of res judicata is thus paramount. On the issue of which ruling prevails if G.R. No. 92248 granted affirmative relief: (This issue is addressed in the preceding points regarding the finality and immutability of judgments, and the lack of authority to alter final decisions.)
Main Doctrine
A final and executory judgment of the Supreme Court cannot be altered or modified, except for clerical errors, misprisions, or omissions. An order of execution that varies the tenor of the judgment or exceeds the terms thereof is a nullity. No inferior court has the authority to revoke a resolution of a superior court, much less a final and executory resolution of the Supreme Court.