Fideldia v. Songcuan
REITERATIONFacts
The Antecedents: Spouses Ray and Gloria Songcuan filed a complaint for specific performance against Petra T. Fideldia to compel her to execute a deed of absolute sale over properties subject to a Conditional Contract of Sale. The trial court ruled in favor of the Spouses Songcuan, ordering Petra to execute the deed and pay damages, which was affirmed with modification by the Court of Appeals. This decision became final and executory on December 4, 1996. Procedural History: Petra Fideldia later donated the properties to her daughter, Leticia T. Fideldia. The Spouses Songcuan sought execution of the final judgment. The trial court initially granted a writ of execution, but later, in an Order dated December 3, 1999, deferred the execution. The Spouses Songcuan filed a petition for certiorari with the Court of Appeals, which annulled the trial court's order deferring execution, directing the trial court to forthwith comply with the rules on execution. The Petition: Petitioners Leticia T. Fideldia and Petra T. Fideldia assailed the Court of Appeals' decision, arguing that subsequent events warranted the deferment of execution and that rescission of the contract was a proper remedy.
Issue(s)
Whether the trial court committed grave abuse of discretion in deferring the execution of the final and executory judgment. Whether subsequent events rendered the execution of the judgment unjust, and the related issue of Leticia and Petra's liability. Whether the remedy of rescission was proper.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed. The presiding judge of the Regional Trial Court, Branch 33, Bauang, La Union is ordered to execute with dispatch the Decision dated 4 November 1991 in Civil Case No. 459-BG, as modified by the Court of Appeals in CA-G.R. CV No. 38855. The Regional Trial Court shall order petitioner Leticia T. Fideldia to execute the necessary deed of conveyance, and to deliver the titles, of the subject properties in favor of the Spouses Ray and Gloria Songcuan.
Ratio Decidendi
On the issue of grave abuse of discretion in deferring execution: The Court held that the trial court committed grave abuse of discretion. It reiterated the principle that once a decision becomes final and executory, it is the ministerial duty of the presiding judge to issue a writ of execution. Exceptions to this rule are limited to instances where subsequent events render execution unjust, which was not the case here. The Court of Appeals correctly annulled the trial court's order deferring execution, directing it to proceed with the execution of the judgment. On whether subsequent events rendered execution unjust, and the related issue of Leticia and Petra's liability: The Court found the petitioners' contentions regarding subsequent events to be untenable. The alleged collection of rentals by the Spouses Songcuan occurred before the decision became final and executory, and any right to these rentals would be resolved in a separate action. Furthermore, the Spouses Songcuan's readiness to pay the balance of the purchase price was supported by the Sheriff's Report and their subsequent consignment of the amount. The primary reason for the Spouses Songcuan's hesitance was Petra's donation of the properties to Leticia after the decision became final, a circumstance that did not render execution unjust, especially given the notice of lis pendens. The Court affirmed the Court of Appeals' ruling that Leticia, as the donee of the properties, is bound by the outcome of the specific performance case because a notice of lis pendens was annotated on the titles to the properties, making any subsequent transferee bound by the pending litigation and its eventual outcome. Therefore, Leticia must execute the necessary deed of conveyance and deliver the titles to the Spouses Songcuan. The Court also affirmed that Petra remains liable to pay legal interest on the amount of damages awarded to the Spouses Songcuan, as modified by the Court of Appeals. This ensures that the prevailing party is compensated for the losses incurred, despite the complications arising from the subsequent donation. On the remedy of rescission: The Court clarified that rescission under Article 1191 of the Civil Code is available only when one of the obligors fails to comply with their obligation. In this case, the Spouses Songcuan were ready and willing to pay the balance of the purchase price. It was Petra who could not comply with her obligation due to the donation of the properties to Leticia. Therefore, Petra was the obligor in default, and the Spouses Songcuan were the injured party, not entitled to rescind. The Court also noted that even if the Spouses Songcuan were in default, the remedy would be to move for execution, not rescission.
Main Doctrine
Once a decision becomes final and executory, it is the ministerial duty of the presiding judge to issue a writ of execution, except in cases where subsequent events render execution unjust. A subsequent donation of the subject property by the judgment debtor does not render execution unjust, especially when the donee is bound by a notice of lis pendens.