G.R. No. 102692 - Johnson and Johnson , Inc. vs. Court of Appeals

The case originated with a complaint filed by petitioner Johnson & Johnson (Phils.), Inc. against spouses Delilah A. Vinluan and Capt. Alejo M. Vinluan.
The complaint was for the collection of an obligation amounting to P235,880.89, incurred by Delilah Vinluan through the purchase of the petitioner’s cosmetic, healthcare, and body care products.
The case was docketed as Civil Case No. 4186 and was tried in the Regional Trial Court (RTC) of Makati, Branch 137.

During several occasions in 1982, Delilah Vinluan purchased Johnson products for her business under the name “Vinluan Enterprises.”
Payment was effected by issuing seven checks, which were subsequently dishonored due to insufficient funds.
A partial payment of P5,000.00 was made on January 5, 1983, reducing the principal debt to P230,880.89, but further payments were not made despite repeated demands.

On June 8, 1983, after several unsuccessful attempts at payment, the petitioner filed the complaint seeking collection of the debt with additional interest, damages, and costs.
On February 5, 1985, the RTC rendered its decision, holding Delilah Vinluan solely liable for the contracted obligation.

The court emphasized that there was no privity of contract between the petitioner and Capt. Alejo M. Vinluan regarding the obligations incurred by his wife.
It was found that the husband neither consented to nor benefited from the transactions, and he did not represent himself as a co-owner of Vinluan Enterprises.
The decision was based on meticulous scrutiny of the evidence demonstrating that the obligations were solely that of the wife.

A writ of execution was issued on February 3, 1989 to enforce the judgment on the defendant’s properties.

On February 8, 1989, notices of levy on execution were issued which erroneously covered not only Delilah Vinluan’s exclusive or paraphernal properties but also the conjugal partnership properties.
Capt. Alejo M. Vinluan responded by filing third-party claims to lift the levy on the conjugal properties and threatened further suit if necessary.
Meanwhile, the petitioner filed a subsequent motion on February 14, 1989 to fix the value of the properties under levy, and further comments were filed by both parties during the ensuing period.
On July 24, 1989, the trial court issued an order fixing the value of the levied personal properties at P300,000.00, denying the third-party claim and the motion to quash the levy on execution.

The Court, referencing Article 117 of the Civil Code, opined that the husband’s consent was implied from his representations and his negotiations regarding settlement.

A second order dated October 4, 1989 reaffirmed the trial court’s determination regarding the alleged liability of the conjugal properties, emphasizing that even if the husband had not expressly consented, any liability could only extend to the conjugal and paraphernal property but not his separate capital.

Capt. Alejo M. Vinluan elevated the matter to the Court of Appeals, charging the trial court with grave abuse of discretion for effectively reversing its own final decision by including the conjugal properties in execution.
The Court of Appeals upheld the trial court’s findings and orders, thus denying the petition for reconsideration by the petitioner.
Petitioner subsequently sought review before the Supreme Court under Rule 45, contending that the trial court’s subsequent orders modified its final and executory decision.

Whether the original decision of the trial court, which exonerated Capt. Alejo M. Vinluan from liability for his wife’s obligations, also absolved the conjugal partnership from liability.

The petitioner argued that the enforcement should have extended to the husband’s capital and conjugal properties due to an alleged ambiguity in the decision.

Whether the subsequent orders (dated July 24, 1989 and October 4, 1989) that affected the execution proceedings effectively amounted to a reversal or modification of the trial court’s final, executory decision.

The petitioner maintained that such orders should be seen as clarificatory, not as altering the substantive final judgment which held only Delilah Vinluan liable.