Title
Fabular vs. Court of Appeals
Case
G.R. No. L-52118
Decision Date
Dec 15, 1982
Petitioner Fabular's land title confirmed; trial court modified writ post-finality, but SC ruled modification void due to lack of jurisdiction.
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Case Digest (G.R. No. L-52118)

Facts:

  1. Application for Registration of Title:

    • Petitioner Perfecto Fabular filed an application for registration of title under Act No. 496 before the Court of First Instance of Leyte, Branch VII, over a parcel of land measuring 1,016 square meters located in Hilongos, Leyte. The case was docketed as L.R. Case No. N-15.
  2. Opposition by Private Respondent:

    • Private respondent Vicente Flandez opposed the application.
  3. Trial Court Decision:

    • After trial, the court rendered a decision on March 17, 1971, confirming Fabular's ownership of the property. The court also ordered Fabular to compensate Flandez P10.00 for two non-fruit-bearing coconut trees planted by Flandez's father on the property.
  4. Finality and Execution of Judgment:

    • The decision became final, and on July 9, 1975, the court issued a writ of execution. Fabular paid Flandez P10.00 as ordered.
  5. Motion for Reconsideration:

    • Two months after the writ of execution and over four years after the decision, Flandez filed a motion for reconsideration on September 3, 1975, claiming ownership of eight coconut trees.
  6. Modification of Writ of Execution:

    • On October 10, 1975, the trial court modified the writ, ordering Fabular to pay Flandez P20.00 per coconut tree for eight trees.
  7. Petitioner's Motion for Reconsideration:

    • Fabular filed a motion for reconsideration on November 18, 1975, arguing that the decision had already become final and executed. The motion was denied on April 20, 1976.
  8. Petition to the Court of Appeals:

    • Fabular filed a petition for certiorari and prohibition before the Court of Appeals, which dismissed it on September 12, 1979, ruling that the trial court's modification conformed to the substance of the original decision and Article 448 of the New Civil Code.

Issue:

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Ruling:

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Ratio:

  1. Finality of Judgment:

    • Once a judgment becomes final, no additions or modifications can be made except for its execution. This principle ensures the finality of judicial decisions and prevents endless litigation.
  2. Dispositive Portion Controls:

    • Only the dispositive portion of a decision is subject to execution. Any statements in the body of the decision serve only as guides or explanations and do not alter the dispositive part.
  3. Jurisdiction After Finality:

    • A court loses jurisdiction to modify a judgment once it becomes final and executed. Any attempt to do so is void for lack of jurisdiction.
  4. Article 448 of the New Civil Code:

    • While Article 448 allows the owner of land to appropriate improvements made in good faith after payment of indemnity, this provision does not apply when the judgment has already become final and executed.


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