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

The identity of the land subject to the judgment can be determined from the pleadings and record if they provide sufficient clues.
If the pleadings do not clarify the identity of the land, extrinsic evidence, whether oral or written, should be considered.
In the absence of a trial or evidence to ascertain the land's identity with certainty, an investigation is necessary, which may include a hearing or ocular inspection by the court or a commissioner.

The court has the authority to direct a reference to a commissioner when a factual question arises during any stage of a case or in executing a judgment.
This authority is applicable even after a judgment has been rendered, as further proceedings may be required to resolve incidental matters related to the execution of the judgment.

A judgment that resolves all substantial merits of a case is final for appeal purposes, but execution may necessitate additional proceedings.
Such proceedings are not a new trial but are supplementary to determine the specific bounds of the land adjudged to the plaintiffs.

The case arose from a sale agreement between Conrado Penson and the Villones, where Penson sold half of his residential land for P1,000.
The Villones made partial payments but faced refusal from Penson to accept the remaining balance, leading to a lawsuit for specific performance.
The court ruled in favor of the Villones, ordering Penson to accept the remaining payment and execute a deed of conveyance.

Following the judgment, Penson offered to convey a specific lot, but the Villones contested the offer, claiming they were entitled to a larger area than what Penson proposed.
The Villones argued that they had been in continuous possession of the larger area and sought a hearing to clarify the land's boundaries.

The court sided with Penson, stating that the Villones' motion to clarify the land's boundaries effectively sought to reopen a case that had already been finalized.
The Villones subsequently filed a petition for certiorari, challenging the court's decision.

The complaint described the land as approximately 500 square meters, while also indicating it was half of a larger parcel assessed under a specific tax declaration.
The conflicting descriptions created ambiguity regarding the actual land sold, complicating the execution of the judgment.

The court recognized that the conflicting descriptions in the complaint rendered the judgment unenforceable without further clarification.
An investigation, including a hearing or inspection, was deemed necessary to ascertain the precise identity of the land sold.

The petition for certiorari was granted, and the court ordered the respondent jud...continue reading