Case Digest (G.R. No. 105805)
Facts:
In Spouses Roberto and Beatriz Garcia v. Spouses Arnel and Cricela Soriano, G.R. No. 219431, decided on August 24, 2020 under the 1987 Philippine Constitution, respondents Arnel and Cricela Soriano filed on February 13, 2004 before Branch 9 of the Regional Trial Court (RTC) in Tacloban City an action for Consolidation of Ownership of Real Property against petitioners Roberto and Beatriz Garcia (Civil Case No. 2004-02-28). After referral to mediation, the parties executed on October 29, 2005 a compromise agreement granting petitioners up to one year to pay ₱300,000.00 to redeem two lots covered by TCT No. T-23868 and TD No. 3582; failure to pay would trigger turnover of Lot 3 (513 sqm) by deed of absolute sale, while petitioners would retain the other parcel. The RTC approved this agreement on June 4, 2007, rendering it a final and executory judgment. Petitioners failed to pay by June 4, 2008. On September 9, 2008, respondents moved for execution. During the January 30, 2009 hearCase Digest (G.R. No. 105805)
Facts:
- Background of the case
- On February 13, 2004, Spouses Arnel and Cricela Soriano (respondents) filed a Complaint for Consolidation of Ownership of Real Property against Spouses Roberto and Beatriz Garcia (petitioners) before the RTC of Tacloban City (Civil Case No. 2004-02-28).
- Mediation was held on September 14, 2005, culminating in a Compromise Agreement dated October 29, 2005, whereby petitioners were given six months to one year to pay ₱300,000 as redemption price for two parcels (TCT No. T-23868 and TD No. 3582), failing which they would convey Lot 3 (513 sqm, TCT No. T-23868) to respondents.
- Approval and failure to comply
- The RTC approved the compromise on June 4, 2007, rendering it a final and executory judgment.
- Petitioners did not pay the ₱300,000 by June 4, 2008, prompting respondents to move for execution on September 9, 2008.
- Post-judgment proceedings and appeals
- January 30, 2009 RTC Order—purportedly “with the permission of respondents”—extended the deadline to April 30, 2009. On April 28, 2009 petitioners manifested willingness to pay, which respondents allegedly refused.
- May 14, 2009 RTC issued the writ of execution; petitioners filed two motions to quash (June 1 and July 28, 2009) which were denied, then partly reversed on January 27, 2010 (ordering respondents to accept payment). Respondents’ reconsideration was denied (April 13, 2010).
- Respondents’ successors-in-interest secured another writ of execution (June 16, 2010). Petitioners sought relief from the CA via certiorari; CA Decision (Dec 2, 2013) and Resolution (Jun 2, 2015) upheld the trial court. Petitioners elevated to the Supreme Court.
Issues:
- Whether petitioners resorted to proper remedies instead of multiple motions to quash the writ of execution.
- Whether the proper party litigants validly entered into a new or modified compromise agreement that superseded the judgment based on compromise.
- Whether the RTC committed grave abuse of discretion in issuing the writ of execution to enforce the judgment based on compromise.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)