Manarin v. Manarin
REITERATIONFacts
The Antecedents: This case originated from a dispute over the estate of Fermin Manarin. Respondent heirs executed an extrajudicial settlement of Fermin's estate, adjudicating a large parcel of land to themselves and excluding petitioner Serafin Manarin, who is also an heir. Petitioner subsequently filed a complaint seeking the annulment of the extrajudicial settlement, cancellation of the title, and declaration as an heir. The parties later submitted a compromise agreement to the Regional Trial Court (RTC), stipulating that they were legitimate descendants, the property would be sold or subjected to a joint venture, the proceeds would be equally shared, and a certain Danilo Sayarot would turn over the owner's copy of the title. Procedural History: The RTC approved the compromise agreement and rendered judgment accordingly, which became final and executory. Disputes arose regarding the execution of this judgment, particularly concerning the owner's duplicate copy of Transfer Certificate of Title (TCT) No. T-741686. The RTC issued several orders to clarify and enforce its decision, including amending the TCT number, ordering Danilo Sayarot to surrender the title, and later declaring the title lost and ordering the issuance of a new one when Sayarot could not produce it. When it was revealed that Fely Panganiban, the attorney-in-fact for the respondent heirs, possessed the title, the RTC ordered her to surrender it, threatening to declare it lost if she failed to comply. The respondent heirs then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's execution orders. The Petition: The Court of Appeals granted the petition for certiorari, nullifying the RTC's execution orders and reinstating the original decision. The CA found that the RTC's subsequent orders varied the terms of the final and executory judgment and that the proceedings for the issuance of a new title did not follow the proper legal procedures. The petitioner, Serafin Manarin, filed this petition for review on certiorari with the Supreme Court, arguing that the CA erred in nullifying the RTC's orders, which he contended were necessary for the execution of the compromise agreement and the expeditious administration of justice. He also argued that the CA should not have given due course to the certiorari petition due to procedural infirmities. The Supreme Court is asked to determine whether the RTC committed grave abuse of discretion in issuing the assailed orders and whether the CA correctly nullified them.
Issue(s)
Whether the Court of Appeals committed a reversible error when it gave due course to the Petition for Certiorari that is procedurally infirm. Whether the Court of Appeals erred in declaring that the RTC committed grave abuse of discretion in issuing the Orders subsequent to the July 27, 2012 Decision. Whether the Court of Appeals erred in failing to consider that the trial court's Orders were in pursuit of expeditious administration of justice. Whether the Court of Appeals erred in declaring that the reissuance of a new owner's copy of TCT No. T-741686 should strictly follow the procedure under Section 109 of Presidential Decree No. 1529.
Ruling
The Supreme Court granted the petition, reversed and set aside the Court of Appeals' decision and resolution, and reinstated the RTC Orders dated September 26, 2017, June 8, 2018, July 13, 2018, and August 31, 2018.
Ratio Decidendi
On the procedural infirmity of the Petition for Certiorari: The Court held that while a motion for reconsideration is generally required before filing a petition for certiorari, an exception exists when such motion would be a futile exercise. In this case, the respondents' failure to file a motion for reconsideration of the August 31, 2018 Order was justified because it was based on the July 13, 2018 Order, making a further motion redundant. Thus, the CA did not err in giving due course to the petition. On the alleged grave abuse of discretion by the RTC: The Court found that the RTC did not commit grave abuse of discretion. The subsequent RTC Orders were issued to execute the July 27, 2012 Decision, which was based on a compromise agreement. The Court emphasized that a writ of execution must strictly conform to the judgment, but amendments correcting clerical errors or clarifying ambiguities necessary for execution are permissible. The amendment correcting the TCT number was a clerical correction, and the order directing Danilo Sayarot to turn over the title to the Clerk of Court was a necessary clarification to resolve ambiguity in the original decision regarding possession and to prevent fraudulent transfers, thereby ensuring the property could be sold as per the compromise agreement. The Court cited the doctrine of immutability of judgment and its exceptions, including the correction of clerical errors and situations where execution would be unjust. On the expeditious administration of justice: The Court found that the RTC's orders were indeed in pursuit of expeditious justice. The ambiguity in the original decision regarding the delivery of the owner's duplicate title led to disputes. The RTC's clarification, directing the title's deposit with the Clerk of Court, was a necessary step to facilitate the sale of the property and equitable distribution of proceeds, as stipulated in the compromise agreement. This action aimed to prevent further litigation and ensure the final judgment was implemented effectively. On the procedure for reissuance of a new owner's duplicate title: The Court clarified that the RTC correctly applied Section 107 of P.D. No. 1529, not Section 109, in its July 13, 2018 Order. Section 107 applies when an owner's duplicate certificate of title is withheld by another person, requiring a court order to compel its surrender. Section 109 applies when the title is lost or destroyed. Since Fely Panganiban was in possession of the title, and her possession was not authorized by the original decision, Section 107 was the appropriate remedy. The RTC's order to Fely to surrender the title, with the consequence of it being declared lost and a new one issued if she failed to comply, was in accordance with Section 107. The Court also affirmed that a motion to compel surrender under Section 107 can be filed as an incident in a pending action, such as the execution proceedings, to avoid multiplicity of suits, citing Ligon v. Court of Appeals.
Main Doctrine
The Supreme Court reiterated that while the writ of execution must strictly conform to the judgment, amendments correcting clerical errors or clarifying ambiguities necessary for execution are permissible, even after finality, provided they do not alter the substantive rights of the parties. Furthermore, the remedy under Section 107 of P.D. No. 1529 for compelling the surrender of a withheld owner's duplicate certificate of title can be availed of as an incident in a pending action, to avoid multiplicity of suits.