Title
Santiago Lopez and Irineo Lopez vs. Hon. Manases G. Reyes, Judge of the Court of 1st Instance of Davao, et al.
Case
G.R. No. L-29498
Decision Date
May 31, 1977
Petitioners sought to modify a writ of execution enforcing a final judgment for an eight-hectare land transfer, but the Supreme Court upheld the decision, citing res judicata and finality of judgment.
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Case Summary (G.R. No. L-29498)

Background of the Case

  • The case involves a special civil action of certiorari filed by Santiago Lopez and Irineo Lopez against Judge Manases G. Reyes, Sheriff Eriberto Unson, and Juan Magallanes.
  • The petitioners sought to nullify an order denying their motion to modify a writ of execution that directed them to segregate an eight-hectare portion of land covered by Original Certificate of Title No. 2990.
  • The original decision in Civil Case No. 2298 ordered the petitioners to segregate the eight hectares and deliver the title to Juan Magallanes, based on a final judgment from the Court of Appeals.

Procedural History

  • The Court of First Instance of Davao dismissed the complaint in Civil Case No. 2298, affirming that the right of ownership over the eight hectares had been decided in favor of Magallanes.
  • The petitioners appealed to the Supreme Court, which affirmed the lower court's decision, establishing that the action to quiet title was barred by res judicata.
  • In 1968, Magallanes filed a motion for execution of the Supreme Court's decision, leading to the issuance of a writ of execution.

Petitioners' Motion to Modify Writ of Execution

  • The petitioners filed a motion to modify the writ, arguing that the writ did not specify the exact area to be segregated and that the actual area covered by the sale was only 64,640 square meters.
  • They contended that the eight hectares mentioned in the contract was an estimate and that the specific boundaries were defined in the sale agreement.
  • The petitioners requested the court to modify the writ to reflect the actual area of 64,640 square meters.

Opposition from Respondent Magallanes

  • Magallanes opposed the motion, asserting that the writ was based on a final and executory judgment that could not be modified.
  • He argued that the sale agreement explicitly stated the sale of eight hectares and that any subsequent survey was made without his knowledge or consent.
  • The opposition emphasized that the trial court lacked the authority to alter the terms of a final judgment.

Court's Denial of the Motion

  • The respondent Judge denied the petitioners' motion, stating that the writ was issued to enforce a final judgment and was beyond his authority to amend.
  • The petitioners' motion for reconsideration was also denied, prompting them to file a petition for certiorari.

Supreme Court's Ruling

  • The Supreme Court found the petition devoid of merit, affirming that the decision in Civil Case No. 2298 was final and executory.
  • The Court reiterated that the petitioners had previously contested the same issue regarding the eight hectares, which had been conclusively decided.
  • The principle of res judicata was applied, preventing the relitigation of the same issue between the same parties.

Legal Principles of Res Judicata

  • The doctrine of res judicata bars the prosecution of a second action upon the same claim or cause of action and precludes relitigation of particular facts or issues.
  • The Court emphasized that a judgment is conclusive on all matters essential to support it, including those necessarily implied in the final judgment.
  • The ruling est...continue reading

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