Prescilla v. Lasquite
REITERATIONFacts
The Antecedents: This case originated from a Complaint for Reconveyance and Damages filed in 1989 by petitioners Simeona, Gloria, and Rodolfo Prescilla, et al., against respondents Conrado O. Lasquite and Juanito L. Andrade. The petitioners claimed to be the tillers and possessors in concepto de dueno of Lots No. 3050 and 3052 since 1940. They alleged that the respondents fraudulently obtained Original Certificates of Title (OCT) No. NP-198 and OCT No. NP-197 for these properties. Subsequently, the Manahan family filed a separate complaint asserting their own title to the property, and Victory Hills, Inc. intervened, claiming ownership. The Regional Trial Court (RTC) initially upheld the Prescillas' ownership of Lot 3052 but sustained the respondents' ownership of Lot 3050, dismissing the cases. Procedural History: The RTC's decision was appealed by the Prescillas, the Manahans, and Victory Hills. The Court of Appeals (CA), Eighth Division, annulled the RTC's decision and declared Victory Hills the owner of Lot 3050, ordering the cancellation of the respondents' titles. The Prescillas filed a motion for reconsideration, while the respondents directly appealed to the Supreme Court (SC) in G.R. No. 175375. The CA, Eighth Division, suspended the resolution of the Prescillas' motion pending the SC's decision. In G.R. No. 175375, the SC reversed the CA's decision, reinstating the RTC's ruling. This decision became final and executory. Subsequently, the respondents filed a motion for execution, which the RTC granted. The Prescillas' motion for reconsideration of this order was denied, leading them to file a petition for certiorari with the CA, Seventh Division, alleging grave abuse of discretion by the RTC. The CA, Seventh Division, dismissed their petition, finding no grave abuse of discretion in the RTC's issuance of the writ of execution. The Petition: The petitioners, Simeona, Gloria, and Rodolfo Prescilla, et al., filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the decision and resolution of the CA, Seventh Division. They argue that the CA erred in not finding that the RTC committed grave abuse of discretion in issuing a writ of execution against them. Their primary contention is that their motion for reconsideration, filed with the CA, Eighth Division, remained pending and unresolved, as its resolution was suspended due to the respondents' appeal in G.R. No. 175375. They assert that under Section 4, Rule 52 of the Rules of Court, the pendency of a timely motion for reconsideration stays the execution of a judgment. Furthermore, they argue that the SC's decision in G.R. No. 175375, which involved only the respondents and Victory Hills, did not resolve the ownership claims between them and the respondents, and therefore, the writ of execution should not have been issued against them as they were not parties to that specific appeal and had not had their day in court regarding that particular SC ruling.
Issue(s)
Whether the RTC committed grave abuse of discretion in issuing a Writ of Execution against petitioners Prescilla, et al. Whether the Supreme Court's decision in G.R. No. 175375 (Lasquite v. Victory Hills, Inc.) is binding on petitioners Prescilla, et al., who were not parties to that case; and the scope of the ruling in G.R. No. 175375. Whether the pendency of petitioners Prescilla, et al.'s Motion for Reconsideration before the CA, Eighth Division, suspends the finality of the judgment as to them; and the applicability of the exception for non-parties to have their day in court, and the procedural complication and due process.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed Decision and Resolution of the Court of Appeals, and vacated the Orders of the RTC. The Court directed the CA, Eighth Division, to resolve petitioners Prescilla, et al.'s Motion for Reconsideration with utmost dispatch.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing a Writ of Execution: The Supreme Court held that the RTC gravely abused its discretion in issuing a Writ of Execution against petitioners Prescilla, et al. The Court emphasized that the pendency of a motion for reconsideration filed on time by the proper party suspends the execution of the judgment or final resolution sought to be reconsidered, as per Section 4, Rule 52 of the Rules of Court. Since petitioners Prescilla, et al.'s Motion for Reconsideration before the CA, Eighth Division, remained unacted upon and unresolved, the controversy had not been resolved with finality as to them, meaning there was no judgment ripe for execution against them. The CA, Seventh Division, erred in disregarding this fact. On the binding effect of the decision in G.R. No. 175375 and the scope of the ruling in G.R. No. 175375: The Supreme Court clarified that the decision in G.R. No. 175375 (Lasquite v. Victory Hills, Inc.) was not binding on petitioners Prescilla, et al. because they were not parties to that case. The Court reiterated the principle that a judgment is conclusive only upon the parties and their successors-in-interest, and a decision does not bind or prejudice a person not impleaded therein, consistent with the constitutional guarantee of due process. The CA, Seventh Division, erroneously concluded that the decision was binding on petitioners Prescilla, et al. despite acknowledging they were not parties, by misinterpreting the scope of the ruling in G.R. No. 175375. The Court stressed that the decision in G.R. No. 175375 did not rule on the ownership claims between petitioners Prescilla, et al. and respondents Lasquite and Andrade. The issues in that case were limited to whether Victory Hills, Inc. was entitled to reconveyance and whether its claim had prescribed. The Supreme Court merely held that Victory Hills failed to prove its entitlement to reconveyance, and it did not pass upon the merits of petitioners Prescilla, et al.'s claim of ownership or resolve the comparative ownership rights between petitioners Prescilla, et al. and respondents Lasquite and Andrade. Therefore, the CA, Seventh Division, erred in believing that the decision in G.R. No. 175375 settled all issues concerning ownership. On the issue of the pendency of petitioners Prescilla, et al.'s Motion for Reconsideration, the applicability of the exception for non-parties, and the procedural complication and due process: The Supreme Court found the CA, Seventh Division's reliance on Suson v. Court of Appeals to be misplaced. In Suson, the non-party had the opportunity to intervene but failed to do so. In the present case, petitioners Prescilla, et al. could not have intervened in G.R. No. 175375 without committing forum-shopping, given that their Motion for Reconsideration was still pending before the CA, Eighth Division, and its resolution was suspended. Thus, they were effectively prevented from having their day in court regarding that specific appeal. The Court noted that the complication arose from the CA, Eighth Division's act of suspending the resolution of petitioners Prescilla, et al.'s Motion for Reconsideration, for which there is no basis in the Rules of Court. This suspension prevented petitioners Prescilla, et al. from exercising their right to appeal, subjecting them to a judgment they had no opportunity to appeal from, which constitutes a violation of due process. The Court emphasized that procedural rules aim for just, speedy, and inexpensive disposition, which was not achieved in this instance.
Main Doctrine
A writ of execution cannot be issued against a party whose motion for reconsideration is still pending and unresolved, as the judgment is not yet final and executory with respect to that party, and to do so would violate due process.