Title
Fabular vs. Court of Appeals
Case
G.R. No. L-52118
Decision Date
Dec 15, 1982
The Supreme Court invalidates lower court orders altering the writ of execution, affirming that final judgments are immutable and only their enforcement is permitted.
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Case Digest (G.R. No. L-52118)

Facts:

  • Perfecto Fabular filed an application for land registration measuring 1,016 square meters under Act No. 496 in Hilongos, Leyte.
  • The application was registered as L.R. Case No. N-15 and opposed by Vicente Flandez.
  • On March 17, 1971, the Court of First Instance of Leyte ruled in favor of Fabular, confirming his ownership.
  • The court ordered Fabular to pay Flandez P10.00 for two non-fruit bearing coconut trees planted by Flandez's father.
  • The decision became final, and a writ of execution was issued on July 9, 1975, upon Fabular's motion.
  • Fabular complied by paying Flandez on July 17, 1975.
  • On September 3, 1975, Flandez filed a motion for reconsideration, claiming ownership of eight coconut trees.
  • The lower court modified the writ of execution on October 10, 1975, ordering Fabular to pay P20.00 per coconut tree.
  • Fabular's motion for reconsideration was denied on April 20, 1976.
  • Fabular then filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed the petition on September 12, 1979.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Perfecto Fabular, reversing the Court of Appeals' decision.
  • The orders dated October 10, 1975, and April ...(Unlock)

Ratio:

  • The Supreme Court stated that once a judgment is final, it cannot be modified or amended, except for execution purposes.
  • The court highlighted that only the explicit terms in the dispositive part of a decision are subject to execution.
  • The March 17, 1971 decision only mandated Fabular to pay P10.00 for two coconut trees, which had already been executed.
  • The ...continue reading

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