Case Summary (G.R. No. L-16744)
Case Overview
- Legal Action: Petition for certiorari with a prayer for a writ of preliminary injunction.
- Petitioner: Simplicio Alinsolorin.
- Respondents: Mateo M. Canonoy (Presiding Judge) and Andrea Salud.
- Court of Origin: Court of First Instance of Cebu, 14th Judicial District.
- Judgment Date: March 31, 1965.
Background of the Case
- Initial Complaint: Filed by Andrea Salud against her husband, Simplicio Alinsolorin, for separation of conjugal properties and return of paraphernal properties (Civil Case No. R-5682).
- Petitioner’s Defense: Denied claims and stated that since both parties were elderly and unable to manage their properties, he appointed their grandson, Julian Suaring, to administer their lands.
- Court Decision: Judgment rendered on July 8, 1959, declared:
- Certain properties as paraphernal properties of Salud.
- Remaining properties as conjugal properties, with Alinsolorin as administrator.
- Alinsolorin required to pay Salud a monthly allowance of P20.00.
Jurisdictional Issue
- Petitioner’s Argument:
- The order issued on January 12, 1960, by the respondent judge was beyond jurisdiction as it altered the final judgment.
- Claimed that the order limited his powers over property administration.
- Argued that the relief granted was not sought in the contempt motion.
Court's Analysis
- Finality of Judgment: The decision in Civil Case No. R-5682 had become executory, obligating Alinsolorin to comply with payment.
- Authority of the Judge:
- The court maintained the authority to enforce compliance with its judgment.
- The sale of conjugal properties aimed to evade obligations under the judgment.
- Order Justification: The judge's order to deposit sale proceeds and pay the monthly allowance was deemed an enforcement measure rather than an alteration of the judgment.
Key Legal Principles
- Compliance with Court Orders: Parties are obliged to comply with final judgments; failure to do so may lead to contempt proceedings.
- Judicial Authority: Courts have the jurisdiction to ensure compliance with their orders and to take necessary actions to enforce them.
Important Details
- Order Issued by Judge on January 12, 1960:
- Required Alinsolorin to deposit proceeds from the sale of conjugal properties.
- Mandated payment of the monthly allowance to Salud from these proceeds.
- Deadline: Alinsolorin was to comply within ten (10) days of receipt of the order.
Key Takeaways
- The Supreme Court upheld the authority of the lower court to enforce compliance with its judgment.
- The petitioner’s attempts to circumvent financial responsibilities through property sales were unsuccessful.
- The cas
Case Syllabus (G.R. No. L-16744)
Case Overview
- This case involves a petition for certiorari filed by Simplicio Alinsolorin against Mateo M. Canonoy, the presiding judge of Branch III, 14th Judicial District, and Andrea Salud.
- The petition seeks to annul the order issued on January 12, 1960, in Civil Case No. R-5682 by the respondent judge, claiming lack of jurisdiction.
Background of the Case
- On August 11, 1958, Andrea Salud initiated Civil Case No. R-5682 in the Court of First Instance of Cebu against her husband, Simplicio Alinsolorin, requesting separation of conjugal properties and the return of her paraphernal properties.
- Simplicio denied the allegations in the complaint and asserted that he appointed their grandson, Julian Suaring, to manage their properties due to their advanced age and inability to do so personally.
- The couple's grandson was responsible for collecting the produce from the lands and was obligated to turn over the proceeds to them.
Judgment of the Court
- After trial, the respondent judge rendered a judgment declaring:
- The first three parcels of land as paraphernal properties of Andrea Salud, granting her immediate possession.
- The remaining five parcels as conjugal properties, with Simplicio remaining as the administrator.
- Simplicio ordered to pay Andrea a monthly sum of twenty pesos as her liquidated share of the c