UPSI Property Holdings, Inc. v. Diesel Construction Co., Inc.
REITERATIONFacts
1. The Antecedents: Respondent Diesel Construction Co., Inc. (Diesel) filed a complaint against petitioner UPSI Property Holdings, Inc. (UPSI) before the Construction Industry Arbitration Commission (CIAC) for the collection of the unpaid balance of a construction contract, retention money, damages for unjustified refusal to grant an extension of time, interest, and attorney's fees. The CIAC rendered an arbitral award in favor of Diesel, ordering UPSI to pay P4,027,861.60 plus legal interest and costs of arbitration. 2. Procedural History: The CIAC judgment was modified by the Court of Appeals (CA), which granted UPSI's claim for liquidated damages and reduced the amount awarded to Diesel. Both parties appealed to the Supreme Court. The Supreme Court, in a consolidated decision, deleted the award for liquidated damages, affirmed the award for the unpaid balance of the contract price to Diesel, ordered UPSI to pay costs of arbitration, awarded attorney's fees to Diesel, and awarded damages to UPSI to be deducted from the retention money or the unpaid balance. This decision became final and executory. Subsequently, Diesel sought the execution of the judgment, which the CIAC granted. UPSI questioned this execution via certiorari before the CA, which denied the petition. Diesel then sought to amend the writ of execution to include legal interest and reimbursement of arbitration costs. The CIAC partially granted this motion regarding legal interest but denied the reimbursement of arbitration costs. UPSI again filed a petition for certiorari with the CA, challenging the CIAC's order to include legal interest. 3. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court was filed by UPSI assailing the CA's decision and resolution that upheld the CIAC's order to include legal interest in the writ of execution. UPSI argues that the Supreme Court's final and executory decision was silent on the award of legal interest, and therefore, the CIAC gravely abused its discretion in modifying the writ of execution by including it. UPSI contends that the issue of legal interest was consistently raised and that the CIAC's inclusion of it substantially varied the terms of the Supreme Court's judgment. Diesel counters that legal interest accrues as a matter of law upon finality of a judgment and that UPSI never raised the issue of legal interest in its previous petitions before the Supreme Court, making it a settled matter.
Issue(s)
Whether the Court of Appeals erred in upholding the CIAC's conclusion that legal interest was deemed included in the amounts awarded by the Supreme Court despite the silence of the dispositive portion of its final and executory judgment. Whether UPSI engaged in forum shopping.
Ruling
The petition is DENIED. The Court of Appeals correctly upheld the CIAC's inclusion of legal interest in the writ of execution.
Ratio Decidendi
On the inclusion of legal interest in the writ of execution: The Court ruled in the affirmative. It reiterated the principle that a final and executory decision is immutable and unalterable. However, in case of ambiguity or uncertainty in the dispositive portion of a decision, the body of the decision may be scanned for guidance. Upon scrutiny of the Supreme Court's decision in G.R. Nos. 154885 and 154937, it was found that there was no intention to delete the award of legal interest. The Court had carefully reviewed the principal amount and liquidated damages, which were specifically questioned, but did not find it necessary to disturb the imposition of legal interest as it was not an issue raised. The CA correctly observed that the Supreme Court's silence on legal interest was not tantamount to its deletion or reversal, especially since the CA's earlier decisions consistently included legal interest, and the Supreme Court did not expressly mandate its deletion alongside the liquidated damages. The CIAC, in denying the reimbursement of arbitration costs, demonstrated its adherence to the rule on immutability of judgment, implying that if the inclusion of legal interest were violative, it would not have granted it. Therefore, the writ of execution must conform to the judgment, and a judgment is not confined solely to its dispositive portion but extends to what is necessarily included therein. On forum shopping: The Court found no legal impediment to the resolution of the controversy. While Diesel pointed out that UPSI had filed another petition for certiorari before the CA (CA-G.R. SP No. 122827) while the present case (CA-G.R. SP No. 110926) was still pending, the CA had already dismissed the earlier petition for being violative of the rule against forum shopping. UPSI refuted the allegation, claiming good faith and disclosure of the pending petition. The Court defined forum shopping and its elements (identity of parties, rights/causes of action, and relief sought). Given that the earlier petition was dismissed for forum shopping, the present petition was not barred.
Main Doctrine
The inclusion of legal interest in a writ of execution is proper even if not explicitly stated in the dispositive portion of a final and executory judgment, provided that the body of the decision and the overall context of the case indicate its inclusion, as the silence of the dispositive portion is not tantamount to its deletion or reversal. A writ of execution must conform strictly to the judgment, but a judgment is not confined to its dispositive portion but extends to what is necessarily included therein.