Dizon-Abilla v. Gobonseng
REITERATIONFacts
The Antecedents: Spouses Carlos and Theresita Gobonseng (respondents) failed to settle a ₱550,000 loan from Gerarda A. Dizon-Abilla and the Heirs of Ronaldo P. Abilla (petitioners). The parties agreed on a settlement where respondents executed a Deed of Sale covering seventeen (17) lots in favor of petitioners, with a separate document granting respondents an option to buy back the lots within six months. Respondents failed to exercise this option. Procedural History: Petitioners filed a case for specific performance, recovery of sum of money, and damages. The Regional Trial Court (RTC) declared the Option to Buy null and void but awarded damages to petitioners for expenses incurred in the preparation and registration of the Deed of Sale, attorney's fees, moral damages, and expenses of litigation. The Court of Appeals (CA) affirmed the RTC decision, holding that the deed of sale and option to buy constituted a pacto de retro sale, but deleted the award of attorney's fees. Nineteen days after the CA decision became final, respondents filed an "Urgent Motion to Repurchase" the lots based on Article 1606 of the Civil Code, tendering payment via deposit. The RTC denied this motion, but a subsequent judge set aside the denial and allowed respondents to repurchase. The CA directed the RTC to implement the repurchase order. The RTC considered the case closed. However, a new judge conducted a hearing in aid of execution, which respondents opposed. The CA, by the challenged Decision, permanently enjoined the RTC judge from conducting further hearings and directed the issuance of a Satisfaction of Judgment. The Petition: Petitioners filed the present petition for review on certiorari, challenging the CA's directive to issue a Satisfaction of Judgment and its permanent injunction against further hearings.
Issue(s)
Whether the Court of Appeals erred in directing the issuance of a Satisfaction of Judgment and permanently enjoining further hearings to prevent endless litigation. Whether the amount tendered by respondents for repurchase was correct and sufficient, and whether this determination had been made with finality. Whether the respondents' belief that the transaction was an equitable mortgage justified the application of Article 1606 of the Civil Code, considering the vendor's bona fide intent.
Ruling
The petition is DENIED. The Court affirmed the Court of Appeals' directive to issue and enter a Satisfaction of Judgment in Civil Case No. 8184 and to permanently enjoin further hearings, sealing the final disposal of the case. The amount tendered by respondents was deemed correct and final.
Ratio Decidendi
On the propriety of the Satisfaction of Judgment and injunction: The Court reiterated the principle that every litigation must come to an end. Once a litigant's right has been adjudicated in a valid final judgment, they should not be granted unbridled license to relitigate. The prevailing party should not be harassed by subsequent suits. The amount tendered by respondents for repurchase had already been passed upon by the appellate court and determined with finality. Therefore, the CA's directive to issue a Satisfaction of Judgment and its permanent injunction against further hearings were proper to prevent endless litigations and ensure the administration of justice. On the correctness of the repurchase amount: The Court noted that the correctness of the amount tendered by respondents had already been passed upon by the appellate court. This determination was made with finality, implying that the appellate court had already reviewed and affirmed the sufficiency of the tender of payment. The subsequent actions of the trial court and the CA were aimed at enforcing this final determination, preventing further disputes over the amount. On the application of Article 1606 of the Civil Code: The Court affirmed its prior resolution in G.R. No. 146651, which held that the applicability of Article 1606 of the Civil Code rests on the bona fide intent of the vendor a retro. If the vendor honestly believed that the transaction was an equitable mortgage, the article applies, allowing repurchase within thirty days from the finality of the judgment declaring the transaction as a sale with pacto de retro. The Court found that the circumstances of the case supported the respondents' belief that the agreement was a mortgage, not an intended sale affecting title, but merely security for an obligation. This belief, founded on attendant facts, justified the application of the provision on conventional redemption.
Main Doctrine
A vendor a retro who honestly believed the transaction was an equitable mortgage may still repurchase the property within thirty days from the finality of the judgment declaring the transaction as a sale with pacto de retro, as the applicability of Article 1606 of the Civil Code rests on the bona fide intent of the vendor a retro.