Guinyawan v. Ayogat
REITERATIONFacts
The Antecedents: Spouses Ayogat filed a case against Spouses Guinyawan for legal or equitable title and possession over a real property. The Regional Trial Court (RTC) ruled in favor of Sps. Ayogat, ordering Sps. Guinyawan to vacate the premises and pay attorney's fees. Sps. Guinyawan appealed to the Court of Appeals (CA), which modified the RTC decision by declaring the land as public land, subject to the right of possession of Sps. Ayogat, and affirmed other aspects. This CA decision became final and executory after this Court denied Sps. Guinyawan's petition for review and motion for reconsideration. Procedural History: Sps. Guinyawan filed a Petition for Annulment of Judgment with the CA, which was dismissed and became final. Subsequently, Sps. Ayogat filed a Motion for Execution. The RTC issued several orders denying Sps. Guinyawan's motions to reset hearings and for reconsideration, and eventually ordered the issuance of a writ of execution. Sps. Guinyawan filed multiple motions for reconsideration and a motion to quash the writ, all of which were denied by the RTC. The writ of execution was partially implemented. The Petition: Sps. Guinyawan filed a Petition for Certiorari, Prohibition, and Mandamus before the Supreme Court, assailing the RTC orders and the writ of execution. They argued that they were denied due process, that the writ of execution varied from the final judgment, and that the RTC judge unlawfully neglected to resolve their opposition and motion to quash. They also invoked Articles 448, 456, and 458 of the Civil Code as alternative relief.
Issue(s)
Whether petitioners were denied due process of law in the issuance of the writ of execution. Whether the writ of execution varied from the final judgment as modified by the Court of Appeals. Whether respondent judge unlawfully neglected to resolve the substance and merits of petitioners' opposition and motion to quash.
Ruling
The petition is DENIED. The assailed orders and the writ of execution are upheld.
Ratio Decidendi
On the issue of due process: The Court found that petitioners were not denied due process. While the RTC initially denied a motion to reset a hearing, it later granted petitioners' motion to set their pending motions for reconsideration and opposition to the writ of execution for hearing. Petitioners' counsel actively participated in this hearing, and the matters were submitted for resolution. The Court reiterated that due process is satisfied when a party is given an opportunity to be heard, whether or not they actually avail themselves of it. In this case, petitioners not only had the opportunity but actually availed themselves of it by presenting their arguments. On the issue of the writ of execution varying from the judgment: The Court found no merit in the contention that the writ of execution varied from the final judgment. A thorough examination of the writ revealed that it carefully limited the enforcement to vesting possession, not title, of the subject land as identified by the RTC and affirmed by the CA. The writ explicitly stated that it was enforcing the judgment "subject to the modification above-stated" by the Court of Appeals, which declared the land as public land. Therefore, the writ did not expand the scope of the judgment. On the issue of unlawful neglect to resolve: The Court found that the RTC judge did not unlawfully neglect to resolve the petitioners' opposition and motion to quash. The records showed that the judge conducted a hearing on these matters, and the petitioners' counsel agreed to submit them for resolution. The subsequent orders denying these motions were issued after such hearing. The argument that the RTC was the appropriate forum to prevent the perversion of judgment was also deemed without merit as the writ itself was found to be in conformity with the final judgment.
Main Doctrine
A writ of execution must conform to the terms of the final judgment; otherwise, it may be quashed. However, procedural due process requires that parties be given an opportunity to be heard, which is satisfied even if the opportunity is not availed of, or if a motion for reconsideration is denied after hearing.