G.R. No. 181353 - HGL Development Corp. vs. Penuela

On November 12, 1996, Crispulo Del Castillo filed a complaint for quieting of title, reconveyance, damages, and attorney’s fees against Jaime Uy (deceased) and Conchita Uy over Lot 791 (TCT No. 29129).
Jaime Uy had died in 1990; the complaint was amended to implead his eight children (Uy siblings). Crispulo died during the action and his heirs were substituted.
On April 4, 2003, RTC Branch 55, Mandaue City, rendered a decision in favor of the substituted respondents, declaring them the owners of Lot 791, nullifying Certificates of Title No. 576 and TCT No. 29129, awarding each petitioner moral damages and litigation costs of ₱20,000, and attorney’s fees equal to 25% of the zonal value of the property.

Petitioners appealed to the Court of Appeals, which affirmed the RTC Decision, and thereafter to the Supreme Court, which denied the petition. The judgment became final and executory on April 8, 2010.
An Entry of Judgment was issued on May 4, 2010.

On August 17, 2010, respondents moved for issuance of a writ of execution, computing attorney’s fees at ₱13,788,250 (25% of zonal value ₱55,153,000) plus moral damages and costs. The RTC granted the motion and issued the writ on December 13, 2010.
On March 21, 2011, the sheriff served a Notice of Garnishment to levy petitioners’ properties to satisfy the judgment.

Petitioners filed an Omnibus Motion to quash the writ and a Motion to quash on jurisdictional grounds, claiming lack of summons and alteration of the RTC Decision.
On December 9, 2011, the RTC nullified the Notice of Garnishment, set a hearing to recompute attorney’s fees, but denied the motion to quash for failure to timely raise jurisdictional issues.
After a January 20, 2012 hearing and position papers, petitioners filed a Consolidated Motion for Reconsideration.
On May 17, 2012, the RTC pegged attorney’s fees at ₱3,387,970 (25% of the 1996 zonal value) and denied reconsideration.

Petitioners elevated the matter by petition for certiorari to the Court of Appeals (CA G.R. SP No. 07120), which in a Decision dated May 26, 2015 affirmed the RTC Orders and, via Resolution on February 22, 2016, denied reconsideration.
Petitioners then filed a petition for review on certiorari before the Supreme Court (G.R. No. 223610).

Whether the Court of Appeals correctly upheld the RTC’s denial of petitioners’ motions to quash the writ of execution and its computation of attorney’s fees.
Whether petitioners were deprived of due process for lack of summons and whether they could be held personally liable beyond their inheritance from their deceased father, Jaime Uy.