Facts:

The case at hand involves Victoria Aguinaldo and Simeona Aguinaldo as the plaintiffs-appellees against the defendants, which include the deceased Segundo Aguinaldo, Primo Aguinaldo, and Rufina Aguinaldo, along with defendants-appellants Cecilio Aguinaldo, Anastacia Aguinaldo, Simplicio Aguinaldo, Domingo Aguinaldo, and Felicitas Bagawisan. The events leading to this litigation began with a decision rendered by the Court of First Instance of Bulacan, Branch II, on March 31, 1958, where Segundo Aguinaldo was ordered to reconvey one-fourth (1/4) of the contested property to the plaintiffs and to pay them an annual amount of P300. This decision was affirmed by the Court of Appeals on May 23, 1965. Following this affirmation, a writ of execution was issued on January 14, 1965. On February 13, 1965, Cecilio Aguinaldo filed a motion to quash the writ of execution, asserting that Segundo Aguinaldo had died on August 7, 1959 while an appeal was pending. The plaintiffs opposed this motion

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Facts:

Chronology and Procedural Background

• On January 14, 1965, the Court of First Instance of Bulacan, Branch II issued a writ of execution based on a decision rendered on March 31, 1958, which ordered defendant Segundo Aguinaldo to reconvey one-fourth (1/4) pro-indiviso of the property to plaintiffs (Victoria Aguinaldo and Simeona Aguinaldo) and to pay them P300.00 yearly beginning in 1955.
• An appeal was filed, and the decision was affirmed by the Court of Appeals on May 23, 1965.
• A motion for the execution of the decision had been granted on January 5, 1965, leading to the issuance of the writ.

Allegation of Procedural Defect and Subsequent Developments

• On February 13, 1965, Cecilio Aguinaldo filed an urgent ex parte manifestation and motion to quash the writ of execution, primarily alleging that defendant Segundo Aguinaldo had died on August 7, 1959 during the pendency of the appeal.
• An opposition to this motion was filed on February 25, 1965, which cited Section 16, Rule 3 of the Rules of Court. This provision mandates that when a party dies, the attorney must promptly notify the court and provide the name and residence of the party’s executor, administrator, guardian, or legal representative.
• In response, the lower court, then presided over by Hon. Ricardo C. Puno, ordered on March 4, 1965, that counsel of record submit by March 22, 1965 the requisite information regarding the legal representative of the deceased Segundo Aguinaldo.
• On March 23, 1965, however, the counsel merely manifested that he had ceased to be the legal representative as of May 31, 1956, and requested that such manifestation suffice as compliance with the court’s order.

Substitution of Defendants

• To prevent the technicality from rendering the final and executory judgment ineffectual, the plaintiffs filed a motion on April 7, 1965 to substitute the heirs of the deceased Segundo Aguinaldo.
• Defendants substituted included Cecilio, Anastacia, Simplicio, and Domingo Aguinaldo—all legitimate children of the deceased—and Felicitas Bagawisan, a granddaughter.
• The lower court, this time presided over by Judge Andres Sta. Maria, granted the motion on October 5, 1965, thereby substituting the above defendants in the place of the deceased.

Appeal and Certification to the Supreme Court

• The defendants, unsatisfied with the substitution, appealed the lower court’s order.
• The Court of Appeals, by resolution of February 17, 1969, certified the matter to the Supreme Court, given that the legal question raised involved a point of law.

Issue:

Whether the lower court erred in substituting the deceased defendant with his legal heirs based on the procedural requirements provided in the Rules of Court.

• Does the failure of the defendants’ counsel to provide complete information regarding the legal representative, as required by Section 16, Rule 3, justify quashing the writ of execution?
• Is the substitution of heirs a valid exercise under the Rules of Court despite the technical lapse by the counsel of the deceased?

Whether the defendants' reliance on a technicality constitutes a valid ground to delay or defeat the enforcement of a final and executory judgment.

• Can a procedural objection, which amounts merely to a technicality, be sufficient to override the enforcement of a judgment that has been duly affirmed by higher courts?

• Whether the principle of finality in litigation requires strict adherence to procedural timeliness, or if judicial discretion should permit the substitution to safeguard the substantive rights of the winning party.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)