Gomez v. Correa
REITERATIONFacts
The Antecedents: Benedicta Mangahas acquired a lot from Philippine Realty Corporation (PRC) via a Contract to Sell. She later conveyed half of her rights to Magdalena Madrid, who in turn assigned her rights to Adelaida Gomez. Benedicta and Adelaida jointly and severally assumed obligations to PRC. Benedicta subsequently sold her remaining rights to Gregorio Correa. Spouses Gomez advanced payments for the entire property, including Benedicta's share. Adelaida Gomez filed a complaint against Benedicta and Correa to rescind the sale to Correa and compel Benedicta to sell her share to Adelaida. Procedural History: The trial court dismissed the complaint for rescission but ordered Correa to reimburse Spouses Gomez P1,600.20 for Benedicta's share, denying claims for damages. On appeal, the Court of Appeals affirmed the reimbursement but directed the trial court to determine the corresponding interest. This Court denied the Spouses Gomez's appeal. Correa offered to pay the amount plus interest, but Spouses Gomez declined. Correa later filed a motion to determine interest due, which the Regional Trial Court (RTC) dismissed, citing the lapse of the five-year period for execution by motion. Correa then filed a new complaint for specific performance, partition, and damages. The RTC ruled in favor of Correa, ordering PRC to deliver the deed of sale, partition the land, fixing interest on P1,060.20, ordering Spouses Gomez to pay costs for surveying, and awarding damages and attorney's fees to Correa. The Court of Appeals modified this, ordering Correa to pay Spouses Gomez specific amounts with interest and attorney's fees, but later amended its decision to have Spouses Gomez pay attorney's fees. The Petition: Spouses Gomez assailed the Court of Appeals' Amended Decision and Resolution, arguing that the appellate court gravely erred in affirming the RTC's modification of the final and executory judgment amount from P1,600.20 to P1,060.20 and in ordering them to pay attorney's fees.
Issue(s)
Whether the Court of Appeals gravely erred in affirming the modification of a final and executory judgment amount. Whether the Court of Appeals gravely erred in ordering the petitioners to pay attorney's fees.
Ruling
The petition is GRANTED. The assailed issuances of the Court of Appeals are MODIFIED. The correct amount to be reimbursed by respondent Gregorio Correa to petitioners Spouses Gomez is P1,600.20, and the award of attorney's fees to respondent Correa is deleted. In all other respects, the challenged issuances are affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of Appeals gravely erred in affirming the modification of the final and executory judgment amount. It reiterated the doctrine of immutability of judgments, stating that once a judgment becomes final and executory, it is immutable and unalterable. The Court emphasized that this principle is founded on public policy and sound practice, ensuring that judgments become final at a definite point in time. The only recognized exceptions are the correction of clerical errors or the making of nunc pro tunc entries, or if the judgment is void, none of which were present in this case. The Court noted that the modification was made by a different court (RTC Caloocan) from the one that rendered the original judgment (CFI of Pasig), further undermining the validity of the modification. The Court pointed out that the amount of P1,600.20 was determined with finality in the prior proceeding, and Correa's own admission acknowledged his obligation to pay this amount plus accruing interest. On Issue 2: The Supreme Court ruled that the award of attorney's fees in favor of respondent Correa was unwarranted. The Court explained that an adverse decision does not automatically justify an award of attorney's fees, as public policy dictates that no premium should be placed on the right to litigate. The records did not show any of the circumstances enumerated in Article 2208 of the Civil Code that would warrant such an award. The Court found that the RTC Caloocan's justification, that the Spouses Gomez's refusal to subdivide the property amounted to bad faith, was insufficient. The burden of proving bad faith was not discharged by Correa, and the refusal to agree to a partition or subdivision was understandable given Correa's failure to settle the correct judgment award, including interest. Therefore, the award of attorney's fees to respondent Correa was deleted.
Main Doctrine
The Supreme Court reiterated the fundamental principle that a final and executory judgment is immutable and unalterable. This doctrine ensures stability and finality in judicial decisions, preventing endless litigation. The Court emphasized that modifications are only permissible for clerical errors or when the judgment is void, and not to correct perceived errors of fact or law. Additionally, the case reinforces the procedural rule that execution of judgment by motion must be filed within five years from its entry, after which a separate action for revival of judgment is necessary.