Gomez v. Correa
REITERATIONFacts
The Antecedents: Benedicta Mangahas (Benedicta) entered into a Contract to Sell with Philippine Realty Corporation (PRC) for a residential lot. Benedicta transferred half of her rights to Magdalena Madrid (Magdalena), who in turn transferred hers to Adelaida Gomez (Adelaida). Benedicta and Adelaida agreed to be jointly and severally liable for obligations to PRC. Benedicta later sold her remaining rights to Gregorio Correa (Correa). Spouses Gomez (Adelaida and husband Tomas) advanced payments for Benedicta's share. Adelaida filed a complaint to rescind Benedicta's sale to Correa and compel Benedicta to sell her share to Adelaida. Procedural History: The Court of First Instance (CFI) dismissed the Spouses Gomez's complaint but ordered Correa to reimburse them ₱1,600.20 for Benedicta's share and dismissed claims for damages. On appeal, the Court of Appeals (CA) affirmed the reimbursement but directed the trial court to determine the corresponding interest. This Court denied the Spouses Gomez's appeal. Correa offered to pay the amount plus interest, but the Spouses Gomez declined. Correa filed a motion to determine interest due, which the Regional Trial Court (RTC) dismissed, citing prescription. Correa then filed a new complaint for specific performance, partition, and damages. The RTC Caloocan ruled in favor of Correa, ordering PRC to deliver the deed of sale, partition the land, fixing interest on ₱1,060.20, ordering Spouses Gomez to pay survey costs, back rentals, damages, and attorney's fees. On appeal, the CA modified the RTC decision, ordering Correa to pay Spouses Gomez specific amounts with varying interest rates and attorney's fees. The CA later amended its decision, denying Spouses Gomez's motion and granting Correa's motion, modifying the award such that Spouses Gomez would pay attorney's fees. The Spouses Gomez filed the present petition. The Petition: The Spouses Gomez questioned the CA's modification of the final judgment amount from ₱1,600.20 to ₱1,060.20 and the award of attorney's fees to Correa.
Issue(s)
Whether the Court of Appeals gravely erred in affirming the modification of the final and executory judgment amount from ₱1,600.20 to ₱1,060.20. Whether the Court of Appeals gravely erred in awarding attorney's fees to respondent Gregorio Correa.
Ruling
The petition is granted. The assailed issuances of the Court of Appeals are modified. The correct amount to be reimbursed by respondent Gregorio Correa to petitioners Spouses Gomez is ₱1,600.20, as decreed by the CFI of Pasig. The award of attorney's fees to respondent Correa is deleted. In all other respects, the challenged issuances are affirmed.
Ratio Decidendi
On the modification of the final judgment amount: The Court reiterated the settled doctrine that a final and executory judgment is immutable and unalterable. It cannot be modified in any respect, even to correct perceived erroneous conclusions of fact or law, except for clerical errors, nunc pro tunc entries, or when the judgment is void. The modification made by the RTC Caloocan, affirming Correa's misrepresentation of the judgment amount, was an error. The prior proceeding in Civil Case No. 4120 before the CFI of Pasig had already determined with finality the amount of ₱1,600.20. Correa himself admitted his obligation to pay ₱1,600.20 plus accruing interest. Therefore, the appellate court erred in affirming the RTC Caloocan's directive to fix interest on ₱1,060.20, which was a modification of a final and executory judgment. On the award of attorney's fees: The Court held that an adverse decision does not automatically justify an award of attorney's fees. Public policy dictates that no premium should be placed on the right to litigate. The records did not show any of the circumstances enumerated in Article 2208 of the Civil Code to warrant the award. The RTC Caloocan's justification that the Spouses Gomez's refusal to subdivide the property amounted to bad faith was not sufficiently proven by Correa. The Court noted that the Spouses Gomez's refusal to agree to a partition or subdivision was understandable given Correa's failure to settle the correct judgment award, including interest. Therefore, the award of attorney's fees to Correa was deleted.
Main Doctrine
A final and executory judgment is immutable and unalterable, and cannot be modified in any respect, even to correct perceived errors of fact or law, except for clerical errors, nunc pro tunc entries, or when the judgment is void. A motion to execute a judgment filed more than five years after its entry prescribes.