G.R. No. 143547 - Potot y Surio vs. People

The controversy stems from a long-running dispute involving the execution of a judgment rendered in Civil Case No. C-9297.
The private respondents, spouses Jose Seelin and Lilia Sevilla Seelin, initiated the case on May 18, 1981, filing a complaint against Central Dyeing & Finishing Corporation for quieting of title and seeking the declaration of nullity of Transfer Certificate of Title (TCT No. 205942).
On August 24, 1989, the Regional Trial Court (RTC) rendered a judgment declaring the defendant’s Certificate of Title null and void and dismissing the defendant’s counterclaim without pronouncing costs.

The RTC decision was affirmed by the Court of Appeals in CA-G.R. CV No. 25989 on June 25, 1991, and later upheld by the Supreme Court in G.R. No. L-101819 on November 25, 1991.
The judgment attained finality on March 5, 1992, permitting private respondents to move for its execution.
The RTC subsequently issued a writ of execution, and later orders addressed further motions by the parties including petitioners’ attempts at reconsideration.

Private respondents, upon the RTC’s order, filed an Urgent Manifestation and Motion for an Immediate Writ of Possession/Break Open Order.
Petitioner Eternal Gardens Memorial Park Corporation intervened by contending:

Its non-involvement in Civil Case No. C-9297, asserting that it was not a party to the suit between the private respondents and Central Dyeing.
Its claim as the true and registered owner, having bought the property from Central Dyeing, and its status as a buyer in good faith.

On July 1, 1992, and again on August 18, 1992, orders were issued holding that the petitioner, as successor-in-interest of Central Dyeing under Rule 39, Section 48(b) of the Revised Rules of Court, was bound by the earlier judgment.

A petition for certiorari was filed with the Court of Appeals but dismissed on September 30, 1992, which was followed by a denial of a motion for reconsideration on February 18, 1993.
On a subsequent appeal, the petitioner’s petition for review on certiorari (G.R. No. 109076) was denied by the Supreme Court on August 2, 1993.
A second motion for execution was later secured by private respondents in an order dated July 20, 1994, leading to further petitions by the petitioner that were eventually dismissed.

On September 29, 1995, the respondent Court of Appeals dismissed the petitioner’s renewed petition for certiorari, emphasizing that:

The judgment in Civil Case No. 9297 had long become final and executory.
The petitioner’s attempts were dilatory and merely an effort to delay execution.

The execution of the final judgment was effectively implemented, as evidenced by the Sheriff’s Return dated March 31, 1995.

Whether a judgment rendered in Civil Case No. C-9297, which has attained finality and been duly affirmed by higher courts, can bind a transferee such as petitioner Eternal Gardens Memorial Park Corporation.

The petitioner argued it was not a party to the original suit and thus should not be compelled to comply with the judgment.

Whether the subsequent legal maneuvers and motions filed by the petitioner, including petitions for certiorari and motions for reconsideration, are sufficient to suspend or delay the execution of the final judgment.

The petitioner contended that post-judgment occurrences rendered the execution of the judgment unjust, illegal, or inequitable.
It further claimed that the execution might disturb the burial lots and affect the rights of lot buyers.

Whether the protection measures ordered by the trial court for the burial lot owners are adequate to safeguard their rights while enforcing the judgment.

The petitioner raised concerns regarding disruption or desecration of the grave sites.

Whether the petitioner’s renewed petition is merely a reiteration of previously decided issues and, thus, constitutes a dilatory tactic contrary to the doctrine of finality and judicial economy.