Title
Solco vs. Provido
Case
G.R. No. 176533
Decision Date
Feb 11, 2008
The Supreme Court upheld Solco's payment as full contract compliance, affirming the trial court's discretion under the Rules of Court on monetary judgment execution.
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Case Digest (G.R. No. 176533)

Facts:

  • Jerome Solco is the petitioner; Claudina V. Provido and Maria Teresa P. Villaruel are the respondents.
  • On April 13, 1989, the Villaruel family executed a Contract to Sell and Memorandum of Agreement with Solco for Lot No. 1454-C in Bacolod City, priced at P3 million.
  • Initial payment of P1.6 million was due upon signing; the remaining P1.4 million was to be paid after clearing the premises within six months.
  • Solco began construction on the property after the contract was executed.
  • On September 19, 1989, the Villaruel family filed a complaint for rescission, claiming Solco violated the agreement by entering without notice and causing property damage.
  • Solco argued that the Villaruels had not fulfilled their obligations, as the structures remained and occupants had not vacated.
  • On March 29, 1996, the RTC ruled in favor of Solco, dismissing the complaint and ordering the Villaruels to vacate and dismantle structures.
  • The Villaruels appealed, and the Court of Appeals modified the RTC's ruling, reducing damages awarded to Solco.
  • After the decision became final on June 12, 2003, Solco filed a motion for execution, which was granted.
  • The Villaruels filed a complaint for cancellation of the contract and damages, leading to further disputes.
  • The RTC accepted Solco's payment of P1,287,786.00 as full compliance, but the Villaruels contested this, prompting an appeal to the Court of Appeals.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition, reversing the Court of Appeals' decision and reinstating the RTC's orders.
  • The Court held that the acceptance of the MBTC check as full payment was valid ...(Unlock)

Ratio:

  • The Supreme Court emphasized that execution is the final stage of litigation; once a judgment is final and executory, issuing a writ of execution is a ministerial duty of the court.
  • The Court noted that the Villaruels' motion to quash the writ of execution was inappropriate, as the sheriff had made several demands for payment from Solco, w...continue reading

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