Paringit v. Bajit
REITERATIONFacts
The Antecedents: Respondents filed a complaint against petitioners for annulment of title and reconveyance of a 150-square meter lot. Respondents alleged that the lot, their family home, was purchased by petitioners from Terocel Realty, Inc. on January 30, 1984, with the understanding that it was for the benefit of all siblings, including respondents, subject to reimbursement of their respective shares in the purchase price. Petitioners advanced the payment, and the title was registered in their name. After the death of their father, Julian Paringit, petitioners demanded back rentals from respondents for their occupancy of the property. Procedural History: The Regional Trial Court (RTC) dismissed the complaint. The Court of Appeals (CA) reversed, holding that an implied trust existed and ordered petitioners to reconvey proportionate shares to respondents upon reimbursement. This Court, in G.R. No. 181844, affirmed the CA decision with modification, ordering respondents to reimburse petitioners P60,000.00 plus legal interest from April 12, 1984, until fully paid. Following the finality of this decision, the RTC issued a writ of execution, but its implementation was delayed by petitioners' motions. The RTC issued orders clarifying that the reconveyance should cover the entire 150 square meters and granting the appointment of a surveyor. Petitioners' motion for reconsideration was denied. The Petition: Petitioners filed a petition for review on certiorari, assailing the CA's decision and resolution, which upheld the RTC's orders. Petitioners argued that the trial court altered the Supreme Court's decision by ordering the segregation of 90 square meters, contending that the lot should be divided into four equal portions or at least 27.5 square meters each. They asserted that a final and executory decision is immutable and unalterable. Respondents countered that there were five siblings involved, and the division should be into five equal shares, with adjustments for Florencio's share. They maintained that they had complied with the reimbursement directive and that the trial court did not vary the Supreme Court's decision.
Issue(s)
Whether the Court of Appeals correctly ruled that the trial court, in ordering the segregation of 90 square meters from the 150 square meter lot, conformed with the terms of this Court's Decision dated September 29, 2010. Whether the trial court, by ordering the segregation of 90 square meters, varied the terms of this Court's Decision dated September 29, 2010.
Ruling
The petition is denied. The Decision dated May 5, 2017, and Resolution dated September 27, 2017, of the Court of Appeals in CA-G.R. SP No. 143060 are affirmed. Petitioners and their counsel are warned against further dilatory actions, and the RTC is directed to promptly implement the Decision dated September 29, 2010.
Ratio Decidendi
On the issue of whether the Court of Appeals correctly ruled that the trial court conformed with the Supreme Court's decision: The Court ruled in the affirmative, holding that the Court of Appeals correctly ruled that the trial court did not alter the terms of this Court's Decision dated September 29, 2010. Instead, the trial court effected a sound and logical implementation of the same. On the issue of whether the trial court varied the Supreme Court's decision: The Supreme Court's decision consistently referred to the subject property as "the lot," encompassing its entirety of 150 square meters, not merely a portion thereof. The evidence presented, including Julian Paringit's affidavit and the conduct of the parties, established an implied trust where petitioners held the lot for the benefit of all siblings. The Court reiterated that the original purchase was for the benefit of Julian and his children, with petitioners advancing the payment and expecting reimbursement. The subsequent actions of petitioners, such as moving out of the house and demanding rent only after their father's death, were inconsistent with a claim of absolute ownership from the outset. The Court found that the trial court's computation of the shares and the need to segregate the respondents' 90 square meter share (30 square meters each for Marciana, Adolio, and Rosario) was a correct application of the Supreme Court's decision, considering there were five siblings (Florencio, Felipe, Marciana, Adolio, and Rosario) involved in the trust. The Court emphasized that the trial court's directive to distribute the entire 150 square meters among the five siblings, with each receiving 30 square meters, was a correct computation based on the established trust and reimbursement obligations. The Court also noted the petitioners' persistent efforts to delay the implementation of the final and executory decision, characterizing it as "contumacious disobedience."
Main Doctrine
The trial court's actions in implementing a final and executory decision, including segregating shares of a property based on established trusts and reimbursements, do not constitute an alteration of the Supreme Court's judgment if they are consistent with its intent and the evidence presented.