Mayon Estate Corporation v. Altura
REITERATIONFacts
The Antecedents: Petitioner Mayon Estate Corporation, along with co-owners Everlasting Estate Corporation (EEC) and NBC Agro-Industrial Development Corporation (NBC), held title to a 150-hectare residential land in Antipolo, Rizal, known as the Peñafrañcia Hills Subdivision. In 1976, the corporations initiated a forcible entry and damages suit (Civil Case No. 890) against Eladio Medina and Ranulfo B. Buensalida, representing farmer's associations, for occupying portions of their land. The Municipal Trial Court (MTC) ruled in favor of the corporations, ordering the defendants to vacate the premises and pay damages. Procedural History: Following the MTC's favorable judgment in 1979, a writ of execution was issued in 1980, but the defendants refused to vacate. Five years later, the MTC granted a writ of demolition, which was partially implemented. In response, the respondents filed a Petition for Prohibition with Writ of Preliminary Injunction & Damages (Civil Case No. 739-A) with the Regional Trial Court (RTC), seeking to halt the demolition, arguing it was issued beyond the five-year period for execution by motion. The RTC initially granted the prohibition, enjoining the MTC's demolition order. Despite this, the petitioner continued to seek alias writs of demolition from the MTC, leading to further demolitions and subsequent restraining orders. The RTC later lifted its writ of prohibition, allowing the MTC to proceed with demolition. The respondents then appealed to the Court of Appeals (CA), which reversed the RTC's order lifting the prohibition, reinstating the finality of the prohibition order. The Petition: The petitioner, Mayon Estate Corporation, seeks review of the Court of Appeals' decision and resolution, arguing that the CA erred in finding that the RTC committed grave abuse of discretion by lifting the writ of prohibition. The petitioner contends that the demolition writs were valid as the five-year period for execution by motion was tolled by the respondents' refusal to vacate. They assert that the RTC's initial prohibition order was erroneous and that the MTC's judgment in the forcible entry case should take precedence. The petitioner is invoking Rule 45 of the Revised Rules of Court to challenge the CA's ruling that the RTC's prohibition order, once final, was immutable and could not be set aside.
Issue(s)
Whether the RTC committed grave abuse of discretion in lifting the writ of prohibition and setting aside its own final and executory decision. Whether a writ of prohibition, once final and executory, takes precedence over an earlier final and executory judgment in a separate case. Whether the five-year period for execution by motion was tolled, validating the subsequent writs of demolition.
Ruling
The petition is denied. The decision and resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of the RTC's authority to set aside its final and executory decision: The Court held that the RTC committed grave abuse of discretion in setting aside its July 28, 1986 decision in Civil Case No. 739-A, which had long become final and executory. The principle of immutability of judgment dictates that once a judgment becomes final, it can no longer be modified or reversed, even if perceived to be erroneous. The RTC's attempt to correct a perceived error in its own prior ruling was an encroachment upon the finality of judgments, which is a cornerstone of the judicial system. The only exceptions are clerical errors or nunc pro tunc entries, none of which were present here. Therefore, the RTC acted without jurisdiction when it attempted to alter a judgment that had attained immutability. On the precedence of the writ of prohibition over the MTC judgment: The Court clarified that the special civil action for prohibition is an original and independent action, separate from the case whose proceedings are being challenged. The RTC's decision in Civil Case No. 739-A, granting the writ of prohibition, became final and executory and thus immutable. This final prohibition order effectively prevented the enforcement of the MTC's decision in Civil Case No. 890. The petitioner's argument that the MTC judgment should prevail because it was rendered earlier in time is misplaced; the finality of the prohibition order created a new legal reality that superseded the enforceability of the MTC judgment through the means previously attempted. On the tolling of the five-year period for execution by motion: The Court found no merit in the petitioner's contention that the five-year period for execution by motion was tolled. The respondents' refusal to vacate the premises, while obstructive, did not legally suspend the running of the prescriptive period for execution by motion. The remedy available to the petitioner after the lapse of the five-year period was to file an independent action to revive the MTC's decision, as provided under Section 6, Rule 39 of the Rules of Court. The petitioner's failure to pursue this proper legal recourse, and its continued attempts to secure demolition writs based on a judgment that could no longer be executed by mere motion, constituted laches. The petitioner's own negligence in failing to act within the prescribed legal periods barred it from assailing the validity of the RTC's final and executory judgment and the writ of prohibition issued pursuant thereto.
Main Doctrine
A final and executory judgment is immutable and unalterable, and cannot be modified even to correct perceived errors of fact or law. The remedy for enforcing a judgment after the five-year period for execution by motion is an independent action to revive the judgment.