Title
Alinsonorin vs. Canonoy
Case
G.R. No. L-16744
Decision Date
Mar 31, 1965
Husband sold conjugal properties to evade court-ordered payments to wife; judge enforced judgment by requiring deposit of sale proceeds.
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Case Digest (G.R. No. L-16744)

Facts:

  1. Parties Involved:

    • Petitioner: Simplicio Alinsolorin
    • Respondents:
      • Mateo M. Canonoy, Presiding Judge of Branch III, 14th Judicial District
      • Andrea Salud (Alinsolorin's wife)
  2. Background of the Case:

    • On August 11, 1958, Andrea Salud filed Civil Case No. R-5682 in the Court of First Instance of Cebu against her husband, Simplicio Alinsolorin, seeking separation of conjugal properties and the return of her paraphernal properties.
    • Alinsolorin denied the allegations and claimed that their grandson, Julian Suaring, was appointed to administer their lands and collect the fruits, with the obligation to turn over the proceeds to them. He also asserted that Salud had been receiving her share of the fruits.
  3. Judgment in Civil Case No. R-5682:

    • The court ruled:
      1. Declared three parcels of land as Salud's paraphernal properties and ordered their immediate return to her.
      2. Declared five parcels of land as conjugal properties, with Alinsolorin remaining as administrator.
      3. Ordered Alinsolorin to pay Salud P20.00 monthly as her share of the produce of the conjugal properties.
    • The judgment became final.
  4. Subsequent Events:

    • Alinsolorin sold the conjugal properties to Julian Suaring for P3,000.00.
    • Salud filed an action to annul the sale.
    • Alinsolorin failed to pay the monthly P20.00 allowance, prompting Salud to file a motion for contempt.
    • During the hearing, Alinsolorin claimed he used the proceeds of the sale for family expenses.
  5. Order of January 12, 1960:

    • The court ordered Alinsolorin to deposit the proceeds of the sale in court within ten days and to use the deposit to pay Salud's monthly allowance.

Issue:

  1. Whether the respondent judge had jurisdiction to issue the January 12, 1960 order requiring Alinsolorin to deposit the proceeds of the sale and pay Salud's monthly allowance.
  2. Whether the order constituted a modification or alteration of the final judgment in Civil Case No. R-5682.
  3. Whether the order improperly limited Alinsolorin's powers of administration over the conjugal properties.
  4. Whether the relief granted in the order was beyond what Salud sought in her motion for contempt.

Ruling:

The Supreme Court dismissed the petition, holding that the respondent judge acted within his jurisdiction in issuing the January 12, 1960 order. The order was a means to enforce the final judgment in Civil Case No. R-5682, which required Alinsolorin to pay Salud P20.00 monthly. The court found that Alinsolorin's sale of the conjugal properties was an attempt to evade his obligations under the judgment. The relief granted in the order was consistent with ensuring compliance with the final judgment.

Ratio:

  1. Jurisdiction of the Respondent Judge:

    • The respondent judge had the authority to enforce the final judgment in Civil Case No. R-5682. The order requiring Alinsolorin to deposit the proceeds of the sale and pay Salud's monthly allowance was a legitimate exercise of this authority.
  2. Finality of Judgment:

    • The judgment in Civil Case No. R-5682 had become final and executory. Alinsolorin was obligated to comply with its terms, including the payment of the monthly allowance.
  3. Enforcement of Judgment:

    • The respondent judge's order was not a modification or alteration of the final judgment but a means to ensure its enforcement. Alinsolorin's sale of the conjugal properties was a clear attempt to avoid his obligations, and the court acted within its authority to prevent this.
  4. Relief Granted in the Order:

    • The relief granted in the order was consistent with the purpose of the motion for contempt, which was to compel Alinsolorin to comply with the final judgment. The court's action was justified to ensure the judgment was carried out.


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