G.R. No. 146754 - Spouses Cachopero vs. Celestial

Petitioner spouses Jesse Cachopero and Bema Cachopero are challenging the actions of respondent Rachel Celestial.
Family relation: Jesse Cachopero is the younger brother of Rachel Celestial.
Real Properties Involved:

Celestial owned an old residential house (old house) located on Lot No. 2586-G-28 (LRC) Psd-105462 in Poblacion 8, Midsayap, Cotabato.
A major portion of the old house stood on a 344-square meter lot (subject land) adjoining Celestial’s lot, originally part of the Salunayan Creek later altered by an irrigation canal.

On July 21, 1989, Celestial filed an ejectment case (Civil Case No. 711) against the spouses Cachopero, alleging that they were occupying her house without proper compensation or tolerance since 1973.
On August 10, 1989, Celestial and the spouses entered into a Compromise Agreement with the following key terms:

The spouses Cachopero were to vacate Celestial’s lot and transfer the old house to the back of Lot No. 2586-G-28 within eight months, not later than April 30, 1990.
Celestial agreed to shoulder all expenses for the dismantling and reconstruction of the old house, sharing fifty percent of the labor and expense costs.
Provision of a two-meter wide exit alley was to be given by Celestial on specified portions of her lot as a road right-of-way.
Both parties agreed to remove their respective improvements from the disputed area.
Both parties waived claims for moral damages and attorney’s fees.

The Municipal Trial Court (MTC) approved the Compromise Agreement on August 10, 1989, rendering it judicially binding.

The spouses were found outside Celestial’s real estate property.
The boundary between the parties’ properties was clearly demarcated.
Improvements introduced by the spouses were already located outside Celestial’s lot.

Despite the general compliance, part of the old house that extended beyond Celestial’s lot was not demolished.
Celestial filed a Motion for the Issuance of an Alias Writ of Execution, alleging non-compliance (i.e., the undemolished portion of the house), which was supported by inspections and the Sheriff’s comments.
The MTC denied both the Motion for Alias Writ of Execution (August 30, 1990) and Celestial’s subsequent Motion for Reconsideration (November 20, 1990), emphasizing that the agreement only contemplated vacating Celestial’s lot.

Celestial subsequently petitioned for mandamus before the Regional Trial Court (RTC), seeking:

An order compelling the MTC to issue an Alias Writ of Execution.
Directing the Sheriff to enforce such writ and ordering the spouses to pay damages, attorney’s fees, litigation expenses, and costs.

The RTC initially dismissed Celestial’s petition (Order issued March 20, 1997) on the ground that mandamus was not available when there was no right being excluded from exercise.
On September 1, 1997, acting on Celestial’s Motion for Reconsideration, the RTC set aside its earlier ruling.
Simultaneously, Jesse Cachopero pursued separate relief through:

A petition (Special Civil Case No. 070) for certiorari, prohibition, and mandamus concerning the Department of Environment and Natural Resources (DENR) denial of his Miscellaneous Sales Application (MSA) over a portion of the subject land.
This petition, along with his subsequent motions, was eventually denied on grounds of lack of merit and failure to exhaust administrative remedies.

On February 3, 1999, the RTC ruled that the issuance of an Alias Writ of Execution in Civil Case No. 711 should be conditioned upon the outcome of Special Civil Case No. 070, as the subject land was also written into the spouses’ application.
Celestial brought the matter to the Court of Appeals, raising issues regarding:

The authority of the RTC to set conditions beyond those in the judgment itself.
Whether tying the execution of the approved compromise to the pending MSA issue was proper.

On September 4, 2000, the Court of Appeals reversed the RTC’s condition by setting aside the RTC’s Order and directing the immediate issuance of an Alias Writ of Execution in the ejectment case, thereby enforcing the entire compromise agreement.
Subsequent petitions for status quo and preliminary injunctions by Celestial were also raised, in response to the spouses’ alleged actions (construction and planting on the subject land).

The spouses Cachopero argued that they had complied with the terms of the Compromise Agreement by vacating Celestial’s lot and, therefore, should not be ejected from the subject land they applied for under the DENR (MSA).
Celestial contended that:

The subject matter of the dispute was solely the old house as covered by the Compromise Agreement.
The partial demolition (with some portions still standing) constituted non-compliance.
The MSA issues were irrelevant to the enforceable terms of the judicially approved compromise.

Ultimately, the dispute centered on whether the judicially approved compromise agreement was to be executed in its entirety despite related pending proceedings (Special Civil Case No. 070/ G.R. No. 142595).

Whether a petition for mandamus will lie to compel the Regional Trial Court (RTC) to issue an alias Writ of Execution in order to enforce the judicially approved Compromise Agreement in Civil Case No. 711.

Is mandamus available to enforce an act that is ministerial and mandated by the approved compromise?
Does the fact that part of the old house remained undemolished amount to a valid ground to withhold execution?

Whether the RTC may lawfully condition the issuance and execution of a writ to eject the parties from the subject land, especially where the ejectment case was strictly limited to the old house on Celestial’s lot.

Can the court extend the scope of the execution beyond the strict terms of the Compromise Agreement?
Does the pending MSA (and the resulting litigation in Special Civil Case No. 070/ G.R. No. 142595) provide a basis for such an extension or for withholding the writ’s issuance?

Whether any supervening events or material changes in the rights or relations of the parties (e.g., the spouses’ MSA with the DENR) justify deviating from the terms of the compromise agreement.