G.R. No. 91885 - Republic vs. Court of Appeals

The Republic of the Philippines (petitioner) contracted with private respondent Laureano Bros., Inc. for plumbing materials intended for use by the National Water and Sewerage Authority (NAWASA).
The procurement was financed by the United States Government through the International Cooperation Administration (ICA).
All materials delivered by the respondent were rejected by NAWASA for failing to conform to the agreed specifications.

Following the rejection of the materials, the Republic initiated a suit against the respondent in the Court of First Instance of Manila (Civil Case No. 44566).
A compromise agreement was reached in which the respondent agreed to pay US$358,882.02, or its equivalent in Philippine pesos.
The conversion rate was judicially fixed at P3.91 per US$1.00 in an earlier Supreme Court decision (G.R. No. L-25055).
The judgment became final and executory on July 27, 1968.

With the judgment rendered and becoming final, the Court of First Instance ordered the attachment of respondent’s property—a 5,000 sq. m. lot with a two-story building along Pasong Tamo Extension in Makati.
A writ of execution was subsequently issued on September 2, 1972, well within the five-year period for enforcing the judgment by motion.
Actual enforcement of the writ was delayed due to various alternative payment proposals made by the respondent, including several requests for an extension of the time to pay.

At the respondent’s request, the petitioner, via the National Economic Development Authority (NEDA), authorized the respondent to look for buyers for the attached property.
Upon receiving a formal offer, the respondent remitted an earnest money payment of P10,000.00 to NEDA.
On April 16, 1973, the trial court issued an order authorizing the sale of the attached property.
Firma Techno Machineries, Inc. purchased the lot and building on May 31, 1973, with the sale deed registered on June 1, 1973.
The respondent remitted net proceeds of P881,004.01 to NEDA after deducting taxes amounting to P68,995.99.

On December 10, 1973, NEDA disapproved of the sale on the grounds that the price was too low and that the conditions imposed by the trial court were not strictly followed.
Consequently, NEDA returned the two checks (the earnest money and the net sale proceeds) and filed an action to annul the sale.
The Court of First Instance nullified the sale due to the undue delay in delivering the net proceeds.
However, the Court of Appeals reversed the trial court’s decision, upheld the sale, and attributed any delay to NEDA’s procrastination in accepting the payment.
The Supreme Court, in case G.R. No. L-52774, ultimately affirmed the validity of the sale.

On November 7, 1985, the petitioner sent a letter of demand for the turnover of the net proceeds of the sale, which was ignored by the respondent.
On May 12, 1986, a motion was filed for the issuance of a writ of execution; however, the trial court denied the motion on the ground that the five-year period for enforcement had lapsed.
The respondent Court affirmed in toto the trial court’s ruling regarding the lapse of the enforcement period.
Petitioners raised issues in a petition for review under Rule 45, challenging whether the period during which the legality of the sale was being litigated should be excluded from the computation of the five-year enforcement period, among other issues.

Whether the period during which the legality of the sale of the respondent’s property was pending before the Court of Appeals and the Supreme Court interrupted or suspended the running of the statutory five-year period for enforcement of the judgment by motion.

Whether the doctrine of estoppel applies to the respondent under the circumstances of the case.

Whether the Court of Appeals’ decision dated November 27, 1989, contradicts its previous decision in CA-G.R. No. 07105 and the Supreme Court ruling in G.R. No. L-52774, which upheld the legality of the sale.