G.R. No. 160109 - Spouses Balanoba vs. Madriaga

The dispute arose from a transaction involving a parcel of land covered by Transfer Certificate of Title (TCT) No. 7815, which was offered for sale by the petitioners, spouses German and Elisa Balabanoba, to respondent Manuel D. Madriaga.
Respondent claimed he had paid a partial amount of P200,000.00 and an additional US$600, with the balance of P250,000.00 to be paid within a specified period.
Before the expiration of the 16-month period for payment, petitioners sold the lot to a third party, Yolanda C. Aguilon, triggering the respondent’s demand to settle the remaining balance.

Respondent filed his action for collection with damages on June 5, 1996, accusing petitioners of failing to reimburse the payments already made and breaching the terms of the sale.
Owing to the petitioners’ failure to file an answer, they were declared in default, and the trial court rendered a decision in favor of the respondent on November 21, 1996.
The decision established a monetary judgment against the petitioners.

On August 9, 2000, respondent initiated execution proceedings by filing a Motion for Issuance of a Notice of Garnishment against petitioners’ property, specifically targeting the garnishment of petitioner German Balanoba’s salary.
Petitioners opposed this motion, arguing issues such as the inclusion of the money judgment as part of the community property with respondent’s wife, Rebecca de Sagon Madriaga.
The trial court initially denied the Motion for Issuance of a Notice of Garnishment on technical and procedural grounds, including non-compliance with Section 5, Rule 15 of the Rules of Court.
Respondent subsequently filed a series of Motions for Reconsideration:

The first motion sought to correct procedural lapses such as the absence of a notice of hearing and discrepancies in the computation of the balance due.
A second motion for reconsideration was submitted, attempting to rectify the discrepancies in the amount collected versus the outstanding balance.
Additional motions were filed in relation to the computation process ordered by the trial court, including a motion for the issuance of an alias writ of execution after the original writ expired.

Meanwhile, on January 3, 2001, respondent’s wife, Rebecca de Sagon Madriaga, filed a Manifestation and Motion contending that the money judgment was part of the conjugal community and that she was entitled to a share, though she also purportedly condoned her share in favor of the petitioners.
The trial court denied her motion on grounds that she was not a party to the case, emphasizing that any waiver of rights during marriage was not permissible without a judicial separation of property.

Petitioners, in a Petition for Certiorari before the Court of Appeals (CA), charged the trial court with abusing its discretion in allowing respondent to file successive Motions for Reconsideration and in denying Rebecca de Sagon Madriaga’s intervention.
The CA upheld the trial court’s ruling, sustaining the series of motions related to the execution of judgment and dismissing the wife’s attempt to intervene.

Whether the rule barring a “second motion for reconsideration” under Section 5, Rule 37 of the Rules of Court applies solely to the losing or “aggrieved party” or to all parties, including the prevailing party.
Whether respondent, as the winning litigant, was improperly restrained from filing a second motion for reconsideration regarding matters attendant to executing the judgment.

Whether Petitioner Rebecca de Sagon Madriaga, by virtue of her marriage to the respondent, had a right to intervene and claim a share of the money judgment.
Whether her post-judgment Motion and Manifestation should be entertained despite the judgment having already become final and executory.

Whether petitioner German Balanoba’s salary is exempt from execution under Article 1708 of the Civil Code by being classified as that of a “mere laborer.”
Whether sufficient evidence was presented to establish that he falls within the class of laborers entitled to such protection.