Salazar v. Felias
REITERATIONFacts
The Antecedents: This case originated from a Complaint for Recovery of Ownership, Possession and Damages filed by the Heirs of Catalino Nivera against Spouses Romualdo and Felisa Lastimosa concerning four parcels of land. During the trial, Romualdo Lastimosa died, and his heirs, including Felicitas Salazar, were substituted. The Regional Trial Court (RTC) ruled in favor of the Heirs of Nivera, declaring them absolute owners and ordering the Heirs of Lastimosa to vacate the property and pay damages. This decision became final and executory as no appeal was filed by the Heirs of Lastimosa. Procedural History: Following the finality of the RTC decision, Felicitas Salazar, along with other heirs, filed a Petition for Annulment of Judgment with the Court of Appeals (CA), alleging deprivation of due process for not being impleaded. The CA dismissed this petition, finding that the original defendants' heirs were bound by the judgment. This ruling was affirmed by the Supreme Court. Subsequently, the Heirs of Lastimosa filed a motion to desist from demolition, claiming Felicitas had an aliquot share. The RTC granted the Heirs of Nivera's motion for execution and demolition. The Heirs of Lastimosa appealed this order to the CA, which dismissed their appeal, ruling that an appeal was the wrong remedy and that the issues raised were already settled by res judicata. The Petition: Felicitas Salazar filed this petition for review on certiorari under Rule 45 of the Revised Rules of Court, seeking to reverse the CA's decision and resolution. She argues that the writ of execution was against the wrong party as she was not impleaded in the original case and was thus deprived of due process. Additionally, she claims the property is exempt from execution as it is her family home. The Heirs of Nivera counter that these issues have been settled by final and executory judgments and that Felicitas has failed to provide evidence to support her family home claim, noting she resides elsewhere and the property has belonged to the Heirs of Nivera since the 1950s.
Issue(s)
Whether the Court of Appeals erred in ordering the execution of the Decision dated March 16, 2004. Whether Felicitas Salazar was deprived of due process for not being impleaded in the original case. Whether the subject property is exempt from execution as a family home.
Ruling
The Supreme Court denied the petition for review on certiorari for lack of merit and affirmed the decision and resolution of the Court of Appeals in toto.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in ordering the execution of the Decision dated March 16, 2004: The Court reiterated the principle that a final and executory judgment is immutable and unalterable. The RTC's decision in the recovery of ownership case had long become final and executory, and a writ of execution was properly issued. The Court cannot refuse to issue, quash, or stay the implementation of a writ of execution based on a final and executory judgment. Parties cannot raise new issues of fact or law to object to the execution, except for specific exceptions not present in this case. The attempt to thwart the execution of a final and executory judgment, rendered thirteen years prior, was deemed a vain and obstinate effort that the Court cannot sanction. On the issue of whether Felicitas Salazar was deprived of due process for not being impleaded in the original case: The Court held that this issue had already been settled with finality in a prior Petition for Annulment of Judgment (CA-G.R. SP No. 95592), which was affirmed by the Supreme Court. The CA had previously ruled that the RTC acquired jurisdiction over the original defendants, Romualdo and Felisa Lastimosa, and thus the outcome of the case was binding on all their heirs. The failure to implead Felicitas was attributed to the defendants themselves, who neglected to include her in their motion for substitution. Therefore, the matter of Felicitas' non-inclusion and the validity of the lower court's judgment were deemed barred by res judicata and could not be relitigated. On the issue of whether the subject property is exempt from execution as a family home: The Court found this claim unsubstantiated. While acknowledging that a family home is generally exempt from execution, the Court emphasized that such a claim must be set up and proven with sufficient evidence, not merely alleged. The claimant must prove that the home was duly constituted, resided in by the family, part of specific property classifications, and within the prescribed value limits. Felicitas failed to adduce any proof to substantiate her claim. Moreover, she admitted to residing in Muñoz, Nueva Ecija, not the subject property. The Court also took judicial notice of the prior ruling that the subject property belonged to the Heirs of Nivera since the 1950s, which negated Felicitas' claim that it was her family home.
Main Doctrine
A claim that property is exempt from execution as a family home must be set up and proven with sufficient evidence; a bare allegation is insufficient to defeat a final and executory judgment. Furthermore, issues already settled with finality by prior judgments are barred by res judicata and cannot be relitigated.