Case Summary (G.R. No. 223610)
Procedural History
Petitioners appealed to the CA and this Court; all remedies were denied, rendering the RTC decision final on April 8, 2010. Respondents moved for a writ of execution to collect attorney’s fees (computed on a P3,500/sqm zonal rate for 15,758 sqm, totaling P13,788,250) plus P20,000 each. The RTC issued the writ on December 13, 2010.
Contentions of Petitioners
Faced with a Notice of Garnishment, petitioners:
- Filed an omnibus motion to quash the writ and re-compute fees, arguing the RTC decision did not specify use of zonal values at execution time.
- Filed a motion to quash on jurisdictional grounds, claiming they were never served with summons and thus the RTC lacked personal jurisdiction.
- Argued they were wrongful impleaded substitutes and that respondents should pursue Jaime’s estate under Rule 3 § 20.
RTC Orders on Writ of Execution
On December 9, 2011, the RTC:
- Granted the omnibus motion as to the Notice of Garnishment, nullifying it and setting a hearing to fix fees.
- Denied the jurisdictional motion for failure to raise the issue earlier.
After hearing position papers, the RTC, on May 17, 2012, computed fees at P3,387,970 (25% of the 1996 zonal value), and denied reconsideration.
Court of Appeals Decision
The CA, in May 2015, upheld the RTC orders. It found:
- Summons were received by petitioners’ counsel (judicial admission), and active participation (answer filed; testimony given) conferred jurisdiction.
- Rule 3 § 20 does not apply because the claim was not purely contractual.
- The writ of execution was valid as it referenced the RTC decision without altering its terms, unlike the Notice of Garnishment which exceeded those terms.
Issues on Jurisdiction and Succession
The Supreme Court framed the issues as:
- Whether the CA correctly upheld the RTC’s denial of jurisdictional challenges and maintenance of the writ of execution.
- Whether petitioners’ liability as heirs should be limited to their inheritance from Jaime under the Rules of Court and Civil Code succession rules.
Supreme Court’s Analysis on Jurisdiction
- Judicial Admissions: Petitioners’ counsel admitted receipt of summons in a 1997 manifestation; such admissions are conclusive.
- Voluntary Submission: Filing an answer, active participation, and appeal constitute voluntary submission to jurisdiction.
- Attorney Authority: No objection was made to counsel’s representation, confirming consent.
Treatment of Heirs’ Liability and Substitution Rules
- Rule 3 § 16 applies only when a party dies during pending proceedings; Jaime died before the case was filed, so his heirs were impleaded in their personal capacities, not as substitutes.
- Rule 3 § 20 concerns contractual money claims and likewise presumes the defendant died while the action was pending; it does not apply here.
- Petitioners successfully litigated the merits and cannot later challenge the judgment’s finality.
Doctrine of Immutability and Equitable Modification
- Final judgments are immutable to ensure certainty, yet courts may relax this in
Case Syllabus (G.R. No. 223610)
Facts of the Quieting of Title Case
- In 1996, Crispulo Del Castillo filed Civil Case No. MAN-2797 for quieting of title, reconveyance, damages, and attorney’s fees over Lot 791 (15,758 sqm.), covered by TCT No. 29129, in the names of Jaime and Conchita Uy.
- Jaime Uy had died in 1990; the complaint was amended in 1997 to implead his eight children (the Uy siblings) and Conchita as defendants.
- During the action, Crispulo died and was substituted by his heirs (respondents).
- On April 4, 2003, the RTC declared respondents as true owners of Lot 791, nullified OCT No. 576 and TCT No. 29129, and awarded P20,000 moral damages and litigation costs each, plus attorney’s fees equal to 25% of the zonal value of Lot 791.
- Petitioners appealed to the CA and sought relief from this Court; both were denied, and the RTC decision became final and executory on April 8, 2010.
Post-Judgment Proceedings and Writ of Execution
- On August 17, 2010, respondents moved for a writ of execution, computing attorney’s fees at P13,788,250 (25% of P55,153,000 zonal value, based on P3,500/sqm).
- The RTC issued the writ on December 13, 2010, and the sheriff’s notice of garnishment sought to levy petitioners’ properties to satisfy P13,788,250 (attorney’s fees) plus P20,000 each (moral damages and costs).
- Petitioners filed an Omnibus Motion to quash the writ and to recompute attorney’s fees, arguing (a) the writ altered the terms of the RTC Decision by using 2010 zonal values and (b) lack of jurisdiction over the Uy siblings for lack of summons.
Orders of the Regional Trial Court
- On December 9, 2011, the RTC:
- Granted the Omnibus Motion in part by