National Housing Authority v. Heirs of Guivelondo
REITERATIONFacts
The Antecedents: This case is an offshoot of a previous expropriation case (G.R. No. 154411) where the Supreme Court resolved the validity of the expropriation of respondents' properties and the payment of just compensation. A writ of execution was issued for ₱104,641,600.00. Various garnishments and releases of funds from different banks occurred, leading to a computed balance of unpaid just compensation. A discrepancy was discovered by the sheriff in his progress report, indicating an unsatisfied amount of ₱70,300.00. Procedural History: Respondents filed a motion for an alias writ of execution to claim the unsatisfied amount and a motion for payment of interest due to a 32-month delay in full satisfaction of the judgment. The case was re-raffled to RTC, Branch 19, after petitioner filed a motion for inhibition. The RTC granted both motions, ordering the issuance of an alias writ for the ₱70,300.00 deficiency and directing petitioner to pay ₱25,695,746.15 as interest. The RTC denied petitioner's motion for reconsideration. The Court of Appeals affirmed the RTC's omnibus order, ruling that the judge was correct in imposing interest and issuing the alias writ. The Petition: Petitioner seeks the reversal of the CA's decision, arguing that the CA erred in affirming the RTC's grant of the alias writ and the motion for payment of interest, contending that the expropriation proceedings were terminated and the original order was silent on interest.
Issue(s)
Whether the RTC, Branch 19, had jurisdiction over the case. Whether the RTC erred in exercising jurisdiction over the motions for alias writ of execution and payment of interest, considering the expropriation case was allegedly terminated. Whether the respondents are entitled to payment of interest on the delayed payment of just compensation, despite the absence of an explicit pronouncement in the original judgment. Whether the issuance of an alias writ of execution for the deficiency in the judgment amount was proper.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the jurisdiction of RTC, Branch 19: The Court held that petitioner is estopped from questioning the jurisdiction of RTC, Branch 19. Petitioner itself filed a motion for inhibition against the presiding judge of RTC, Branch 11, which led to the re-raffling of the case. Furthermore, petitioner actively participated in the proceedings before Branch 19 by filing motions and opposing the respondents' motions. To allow petitioner to question jurisdiction after actively participating in the proceedings would be to countenance the undesirable practice of a party accepting a judgment if favorable and attacking it for lack of jurisdiction if adverse. The principle of estoppel bars petitioner from raising this issue. On the RTC's exercise of jurisdiction over the motions: The Court reiterated the well-settled principle that the jurisdiction of a court to execute its judgment continues even after the judgment has become final, for the purpose of enforcement. The present case was no exception. Therefore, notwithstanding the final resolution on the validity of the expropriation, RTC, Branch 19 could still rule on the motions for alias writ of execution and payment of interest. The duty of the court extends to enforcing its decisions to the fullest extent of their intent and mandate, preventing the decision from being trivialized or rendered meaningless. On the payment of interest: The Court found petitioner's theory implausible. The doctrine cited by petitioner (Dalmacio Urtula v. Republic of the Philippines) concerning res judicata and the waiver of interest in expropriation cases was distinguished. In Urtula, the interest claimed was part of the just compensation, which should have been raised during the expropriation proceedings. In the present case, the interest claimed by respondents is legal interest imposed due to the delay in the payment of a money judgment, which accrues by operation of law and does not need to be explicitly stated in the judgment. This type of interest is considered a consequence of the forebearance of credit during the interim period from the finality of the judgment until its satisfaction. Therefore, the award of such interest was proper. On the validity of the alias writ of execution: The Court affirmed the CA's finding that there was no irregularity in the issuance of the alias writ. The rule is that a writ of execution must substantially conform to the judgment. In this case, the sheriff discovered a deficiency of ₱70,300.00 in the execution of the judgment. Upon the sheriff's report of this deficiency, an alias writ of execution covering the shortfall was proper to ensure the faithful execution of the judgment and preserve its tenor.
Main Doctrine
The jurisdiction of a court to execute its judgment continues even after the judgment has become final for the purpose of enforcement. An alias writ of execution is proper to enforce a deficiency in the execution of a judgment. Interest imposed due to delay in the payment of a money judgment is a legal interest that accrues by operation of law and need not be explicitly stated in the judgment, unlike interest awarded as part of just compensation in expropriation cases.