G.R. No. 143781 - Clavano, Inc. vs. Housing and Land Use Regulatory Board

Private respondents, spouses Enrique and Venus Tenazas, filed a complaint for specific performance against petitioner Jose Clavano, Inc. with the Housing and Land Use Regulatory Board (HLURB) to compel the execution of a contract to sell a house and lot.
Petitioner claimed that the spouses defaulted on their obligation to pay the balance of the purchase price.
The HLURB ruled in favor of the spouses, a decision upheld by the Office of the President, which deleted the award of moral damages.
The decision became final and was executed, leading to further motions by the spouses regarding expenses for notarization and title transfer.

On March 23, 1999, the spouses filed a motion with HLURB to compel petitioner to pay for notarization and title transfer expenses.
HLURB granted the motion, leading to a denial of petitioner's motion for reconsideration.
Petitioner appealed to the Court of Appeals, which affirmed HLURB's orders, prompting the current petition for certiorari.

Petitioner denied any obligation to pay for the expenses, asserting that neither the contract nor the HLURB decision imposed such a duty.
Petitioner contended that the HLURB's orders exceeded its authority and effectively modified the final decision, which was void and unenforceable.

The court emphasized that the HLURB and Court of Appeals could not amend a final decision that had already been executed.
The proper remedy for challenging such modifications is a petition for certiorari under Rule 65 of the Rules of Court.

The HLURB's subsequent orders requiring payment for expenses did not align with the original decision and were deemed invalid.
Execution must conform to the dispositive part of the judgment; any order exceeding this is void.

The obligation to execute a deed of sale and deliver a title does not inherently include the obligation to pay for related expenses.
The terms of the original decision did not imply that petitioner was responsible for the costs of notarization or title transfer.

There was no basis in the HLURB decision or the pleadings for requiring petitioner to pay the expenses claimed by private respondents.
The court referenced previous cases where obligations not included in the dispositive portion of a judgment could not be enforced.

The HLURB and Court of Appeals could not impose new obligations not raised in the original complaint.
A judgment must be supported by the pleadings and evidence presented during the trial.

The complaint only sought specific performance of the contract and did not request reimbursement for expenses.
The court ruled that remedies sought must be explicitly stated in the pleadings.

The HLURB's procedure of allowing private respondents to seek additional relief through a motion during execution was improper.
The court reiterated that new claims or evidence cannot be introduced at this stage.