Sia v. Villanueva
REITERATIONFacts
The Antecedents: This case stems from a dispute over a 2,154 square meter parcel of land in Naga City, originally owned by Don Macario Mariano. Following his death, his widow, Irene, entered into a joint venture for a memorial park, which failed. Irene subsequently filed a complaint for rescission of contract against her joint venture partner, Francisco Bautista. The Regional Trial Court (RTC) ordered rescission, and the Court of Appeals affirmed with modification, ordering Irene to reimburse Bautista for development costs and cash advances. Due to Irene's failure to comply, the subject lot was levied on execution. Unbeknownst to some, Irene had previously sold the lot to Raul Santos in 1975, leading to a new title being issued in Santos' name. Irene passed away in 1988, and her adopted children, Jose and Erlinda, filed a complaint to annul the sale to Santos. Meanwhile, in the rescission case, the sheriff sold the lot at public auction to Ruben Sia, the petitioner, who received a provisional deed of sale. Procedural History: Erlinda Villanueva, the sole surviving heir after Jose's death, attempted to redeem the property from Ruben Sia, but Sia refused her payment, prompting Erlinda to consign the redemption price with the court. Erlinda later sold the lot and its improvements to lessees, contingent on her redemption. The sheriff issued a Final Deed of Sale to Sia, who then obtained a new title in his name. Erlinda filed a petition for mandamus to compel acceptance of her redemption money, which was denied by the trial court. She then filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed her petition, declaring Sia the rightful owner. Erlinda appealed to the Supreme Court (G.R. Nos. 94617 and 95281). On April 12, 2000, the Supreme Court annulled the Court of Appeals' decision, ordering the sheriff to accept Erlinda's redemption payment and nullifying the deed of sale to Sia. This decision became final and executory on October 16, 2000. The trial court then issued a writ of execution to enforce the Supreme Court's ruling. Ruben Sia filed a petition for certiorari with the Court of Appeals, assailing the trial court's order for execution. The Court of Appeals dismissed Sia's petition, which he then sought to have reviewed by the Supreme Court. The Petition: Petitioner Ruben Sia filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' Decision dated January 7, 2002, which dismissed his petition for certiorari. Sia argued that the Court of Appeals erred by failing to address the sole issue he raised: whether Erlinda's right to redeem pertained to the entire lot or only a portion thereof. The Supreme Court, however, found that Sia pursued the wrong remedy, as certiorari is only available when a lower court acts without or in excess of jurisdiction or with grave abuse of discretion, and no other plain, speedy, and adequate remedy exists. The Court reiterated that after a judgment becomes final and executory, the lower court's duty is ministerial, limited to enforcing the decision. The Court noted that the dispositive portion of its prior decision did not limit Erlinda's redemption to a portion of the lot, and if Sia had doubts about its execution, his proper remedy was a motion for clarification, not a petition for certiorari. Therefore, the Supreme Court denied Sia's petition, affirming the Court of Appeals' decision in toto.
Issue(s)
Whether the Court of Appeals erred in dismissing Ruben Sia's petition for certiorari. Whether Erlinda's right to redeem pertains to the entire lot or only a portion of it.
Ruling
The Supreme Court denied the petition and affirmed the Court of Appeals' Decision in toto. The Court held that the trial court acted within its ministerial duty in issuing the writ of execution to enforce the final and executory Supreme Court decision. The Court clarified that Erlinda's right of redemption pertains to the entire 2,154 square meter prime land and the improvements thereon, as specified in the Supreme Court's prior decision.
Ratio Decidendi
On the propriety of the certiorari petition: The Court of Appeals correctly declared that petitioner Ruben Sia pursued the wrong remedy. A special civil action for certiorari under Rule 65 is available only when a tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, and there is no other plain, speedy, and adequate remedy. In this case, the trial court was merely performing its ministerial duty to enforce a final and executory Supreme Court decision. The Court reiterated the doctrine that after a final judgment, it is the duty of the court to enforce it according to its terms, and its only function is the ministerial act of carrying out the decision and issuing the writ of execution. Therefore, the trial court did not act with grave abuse of discretion. On the scope of Erlinda's right to redeem: The Court noted that the dispositive portion of the Supreme Court's Decision in G.R. Nos. 94617 and 95281 did not state that Erlinda's right to redeem was limited to a portion of the subject lot. If petitioner Ruben Sia felt that the dispositive portion was vague, his proper remedy was not to file a petition for certiorari, but a motion for clarification. This is considered a plain, speedy, and adequate remedy. The Court clarified that the property levied upon in Civil Case No. R-570 consisted of a "2,154 square meter prime land and the ancestral house and commercial building standing thereon." Thus, Erlinda's right of redemption clearly applies to the entire property.
Main Doctrine
A trial court's issuance of a writ of execution to enforce a final and executory Supreme Court decision is a ministerial duty and does not constitute grave abuse of discretion. If a party believes the dispositive portion is vague, the proper remedy is a motion for clarification, not a petition for certiorari.