G.R. No. L-1372 - Villones vs. Nable

On December 30, 1940, Conrado Penson sold or promised to sell one half of his residential land in Talavera, Nueva Ecija, to Alipio Villones, Aurelio Villones, and Catalina Villones for P1,000.
The purchasers paid Penson fifty cavanes of palay as an advance payment, with the balance to be settled in March 1941.
In 1941, Penson received additional payments ranging from P20 to P50 in cash from the Villones.

On March 4, 1946, the Villones filed a complaint for specific performance against Penson, alleging that they had paid P425 of the P1,000 purchase price, leaving a balance of P575.
They claimed that Penson refused to accept the balance in 1942 (due to the use of Japanese war notes) and again in February 1946 (in Philippine legal currency), stating he no longer wished to sell the land.

Penson filed a general denial in response to the complaint.
Judge Sotero Rodas rendered a judgment on the pleadings on May 17, 1946, ordering Penson to accept the P575 balance and execute a deed of conveyance for the land sold to the Villones as of December 30, 1940.

Penson did not appeal the judgment.
On September 20, 1946, Penson filed a motion stating his willingness to accept the P575 and execute a deed of conveyance for one half of his land covered by Tax Declaration No. 18229 (1,000 square meters).
The Villones opposed the motion, claiming they were entitled to one half of the entire 4,715 square meters of Penson’s land, not just the 1,000 square meters under Tax Declaration No. 18229.
The Villones requested a hearing and the appointment of the provincial sheriff to inspect the land.

Judge Mariano Nable sustained Penson’s objection, ruling that the Villones’ motion would amount to reopening the case after the judgment had become final and executory.
The Villones then filed a petition for certiorari with the Supreme Court.

The complaint described the land as "residential land about 500 square meters, more or less," bounded by specific landmarks, and stated it was one half of the land under Tax Declaration No. 18229.
However, the boundaries provided in the complaint suggested an area of over 2,000 square meters, conflicting with the 500 square meters mentioned.

Finality of Judgments: A judgment that has become final and executory cannot be reopened or modified, except for clerical errors or to resolve ambiguities in its execution.
Aid of Execution: Courts may conduct supplementary proceedings, such as hearings or inspections, to clarify ambiguities in the description of property subject to a judgment, provided these proceedings do not reopen the case or alter the substantive rights of the parties.
Conflict in Land Description: When a judgment contains conflicting descriptions of the land (e.g., area vs. boundaries), extrinsic evidence may be used to resolve the ambiguity and ensure the judgment is enforced fairly.
Rule 34, Section 2(c): This rule authorizes courts to direct references to commissioners or conduct hearings to resolve factual issues arising in the execution of judgments, ensuring that the judgment is carried out effectively.

Justice Paras dissented, arguing that the Villones were estopped from claiming more than 500 square meters, as their complaint and the final judgment were based on the sale of one half of the land under Tax Declaration No. 18229.
He contended that the investigation ordered by the majority should be limited to determining the boundaries of the 500 square meters and not allow the Villones to claim a larger area.
He emphasized that the final judgment should not be substantially altered or reopened through supplementary proceedings.