G.R. No. 213421 - Unirock Corp. vs. Carpio

Unirock Corporation, represented by Edison U. Ojerio, is the petitioner in this case, while Armando C. Carpio and Hardrock Aggregates, Inc. are the respondents.
The dispute centers on properties originally titled in Unirock’s name, which were subject to a real estate and royalty controversy.

Respondents initially filed a complaint for quieting of title against Unirock before the RTC-Br. 71, later transferred to RTC-Br. 73, under Civil Case No. 94-3393.
The case was elevated before the Supreme Court (docketed as G.R. No. 141638) and resulted in a final judgment in favor of Unirock, confirming its ownership over the subject properties.
Entry of Judgment was entered on January 7, 2002.

During execution proceedings at RTC-Br. 73, Unirock and Hardrock entered into a Memorandum of Agreement (MOA).

Unirock, as the adjudged owner, granted Hardrock the exclusive right to quarry the mineral resources within the subject properties.
In consideration, Hardrock undertook to pay royalties to Unirock corresponding to the extracted quarry materials.

The MOA explicitly recognized Unirock’s absolute ownership, citing a Supreme Court decision, and outlined provisions for:

Hardrock, in connection with the MOA, applied for a Mineral Production Sharing Agreement (MPSA) with the Mines and Geosciences Bureau (MGB) of the DENR, relying on Unirock’s consent and approval as documented in the MOA.

A third party, Teresa Gonzales, filed a separate complaint for nullification of title against Unirock and Hardrock before RTC-Br. 74 (Civil Case No. 06-7840), asserting an ownership claim and seeking, among other remedies, that Hardrock pay royalties to her instead.

RTC-Br. 74 ordered Hardrock to deposit the royalty payments into an escrow account pending the resolution of her complaint.
This case was eventually dismissed on January 11, 2008, but the resolution remained pending on appeal before the Court of Appeals.

Unirock pursued remedial action by filing a complaint for rescission of the MOA along with claims for royalty payments and damages under Civil Case No. 06-7891, which was dismissed for improper venue.

On October 30, 2008, Unirock filed a motion for issuance of a writ of execution in Civil Case No. 94-3393, asserting that Hardrock failed to pay the royalties per the MOA.

In response, Hardrock contended that the filing of Civil Case No. 06-7840 by Gonzales raised doubts about Unirock’s title, alleging misrepresentation that made the execution of the judgment unjust and inequitable.
Hardrock also referenced that the MOA was cancelled by the DENR-POA in relation to its administrative proceedings.

RTC-Br. 73, in an Order dated July 8, 2009, denied Unirock’s motion for execution on the ground that it was premature.

The court found that Unirock’s evidence (a photocopy of a “Quarry Materials Withdrawals Summary”) was insufficient to substantiate its claim for unpaid royalties amounting to P34,718,026.25.
It noted that Unirock had already initiated a separate case for rescission of the MOA, which was dismissed on procedural grounds, leaving the substantive issues unresolved.
The court also held that since Civil Case No. 06-7840 was pending, adjudication on the issue of ownership—and consequently, on royalty entitlement—remained unsettled.

The Court of Appeals (CA) affirmed the RTC’s ruling in a Decision dated February 25, 2014, agreeing that:

The submitted evidence was inadmissible.
The supervening proceedings in Civil Case No. 06-7840 complicated the execution of the compromise judgment.
Unirock was not facing unjust prejudice given that an escrow order was already in place pending the resolution of the ownership issue.

Unirock’s subsequent motion for reconsideration was denied in a Resolution dated June 30, 2014, prompting the current petition for review.

Whether the denial of Unirock’s motion for issuance of a writ of execution, based on the asserted non-payment of royalties under the MOA, was correct.

Did Unirock provide sufficient admissible evidence to prove Hardrock’s failure to pay the royalties as agreed?
Does the filing of Civil Case No. 06-7840 by Teresa Gonzales, which raised questions on the title, affect the execution of the final compromise judgment in Civil Case No. 94-3393?
Can Hardrock legitimately assert that Unirock misrepresented its ownership of the subject properties, thereby rendering the execution unjust and inequitable?

Whether the principles underlying compromise judgments and res judicata preclude re-litigation of the ownership issue and, by extension, should allow enforcement of the final judgment despite the pending proceedings in Civil Case No. 06-7840.