The Supreme Court held that once a judgment becomes final and executory, it is immutable and unalterable, thus an order of execution is not appealable. This principle ensures that litigation reaches a definitive end, preventing endless relitigation of settled issues. The Court emphasized that allowing appeals on execution orders would undermine the stability of judicial decisions and deny prevailing parties the fruits of their victory, preventing the losing party to continue devising schemes to delay the execution of the court’s ruling.

Surveying the Boundaries of Finality: When is an Execution Order Really Final?

In Agdao Landless Residents Association, Inc. vs. Jimmy Eugenio, et al., the central legal question revolved around whether an order from the Municipal Trial Court in Cities (MTCC) pertaining to a survey report conducted by a court-appointed commissioner during the execution phase of a case could be appealed. The Agdao Landless Residents Association, Inc. (ALRAI) originally filed an unlawful detainer case against Jimmy Eugenio, Henry Eugenio, Lovell Eugenio, Tomas Perales, and Elena Corgio (Eugenio, et al.), asserting ownership over 15 parcels of land in Bo. Obrero, Davao City, which the Eugenios allegedly occupied without membership in the association. ALRAI won the original unlawful detainer case, but during the execution phase, Eugenio, et al. filed a motion to clarify the areas to be vacated, which prompted a resurvey of the property. This resurvey led to conflicting reports, one favoring ALRAI and the other favoring Eugenio, et al., ultimately leading to the contested order.

The heart of the Supreme Court’s analysis was the principle of the immutability of judgments. The Court reiterated that a final and executory judgment becomes the law of the case, binding on all parties and no longer subject to modification, except for clerical corrections or nunc pro tunc entries. This principle is crucial for maintaining the stability and finality of judicial decisions. The Court stated:

Settled is the rule that when a judgment is final and executory, it becomes immutable, unalterable, and may no longer be modified in any respect, except to correct clerical errors or to make nunc pro tunc entries, or when it is a void judgment. A judgment that has attained finality becomes the law of the case regardless of claims that it is erroneous.

Building on this principle, the Court highlighted that an order granting a motion for a writ of execution is generally not appealable. According to Section 1, Rule 39 of the Rules of Court, once a judgment is final, the issuance of a writ of execution is a ministerial duty of the court, ensuring that the prevailing party receives the benefits of the judgment. Section 1(e) of Rule 41 explicitly prohibits appeals from orders of execution. This prohibition is rooted in sound public policy, aimed at bringing litigation to a definitive end.

The Court acknowledged that there are exceptions to this rule, such as when the writ of execution varies the judgment, when there has been a change in the situation of the parties making execution inequitable, or when the writ has been improvidently issued. However, the Court found that none of these exceptions applied to the case at hand. The Court noted that Eugenio, et al. had already had the opportunity to argue their case before the Regional Trial Court (RTC), which affirmed the MTCC’s ruling in favor of ALRAI. The motion to clarify during execution was merely an attempt to relitigate issues that had already been settled.

Moreover, the Court emphasized that the survey conducted by the court-appointed commissioner, which favored ALRAI, was valid, while the survey conducted by Eugenio, et al.’s commissioner was done without proper notice to all parties. Therefore, the MTCC did not commit grave abuse of discretion in denying Eugenio, et al.’s Notice of Appeal. To further clarify the matter, it is important to know the exceptions to the non-appealability of orders of execution. The following table summarizes the exceptions:

Exception	Description
Writ varies the judgment	The execution order alters or contradicts the original judgment.
Change in circumstances	A significant change in the parties’ situation makes the execution unjust.
Exempt property	Execution is attempted against property that is legally exempt.
Controversy submitted	The case was never properly brought before the court for judgment.
Unclear terms	The judgment’s terms are vague, requiring interpretation.
Improvident issuance	The writ was issued improperly, defectively, or against the wrong party.

In its decision, the Supreme Court reversed the Court of Appeals’ ruling, reinstating the MTCC’s order and the special writ of demolition. The Court underscored that allowing appeals from execution orders would undermine the principle of finality and allow losing parties to indefinitely delay the enforcement of judgments. The implementation and execution of judgments that had attained finality becomes ministerial on the courts. Public policy also dictates that once a judgment becomes final, executory, and unappealable, the prevailing party should not be denied the fruits of his victory by some subterfuge devised by the losing party.

FAQs

What was the key issue in this case?	The key issue was whether an order related to a survey report during the execution phase of an unlawful detainer case could be appealed. The Supreme Court ruled that it could not, reinforcing the principle of the immutability of final judgments.
What is the principle of immutability of judgments?	The principle states that once a judgment becomes final and executory, it can no longer be modified or altered, except for clerical corrections or when the judgment is void. This ensures stability and finality in legal proceedings.
Why are orders of execution generally not appealable?	Orders of execution are not appealable because they are part of the process of enforcing a final judgment. Allowing appeals would undermine the finality of the judgment and prolong litigation indefinitely.
What exceptions exist to the rule against appealing execution orders?	Exceptions include when the writ of execution varies the judgment, when there’s a change in the parties’ situation making execution inequitable, or when the writ has been improvidently issued. However, these exceptions are narrowly construed.
What was the MTCC’s role in this case?	The MTCC initially ruled in favor of ALRAI in the unlawful detainer case and later issued an order approving the survey report of the court-appointed commissioner. The MTCC’s denial of Eugenio, et al.’s Notice of Appeal was upheld by the Supreme Court.
How did the Court view the motion to clarify filed by Eugenio, et al.?	The Court viewed the motion to clarify as an attempt to relitigate issues that had already been settled during the trial and appeal stages. It was seen as a delaying tactic rather than a legitimate effort to clarify ambiguities in the judgment.
What was the significance of the survey reports in this case?	The survey reports were crucial in determining whether Eugenio, et al.’s properties encroached on ALRAI’s titled land. The court favored the report of the court-appointed commissioner, which showed encroachment, over the report commissioned by Eugenio, et al.
Can a party raise new issues during the execution phase?	No, parties cannot raise new issues of fact or law during the execution phase, except in very limited circumstances. The execution phase is for implementing the judgment, not for reopening the case.
What is the effect of the Supreme Court’s decision on Eugenio, et al.?	The Supreme Court’s decision means that Eugenio, et al. must vacate the properties they occupy, as the special writ of demolition issued by the MTCC is reinstated. They cannot further delay the execution of the judgment.

This case reinforces the critical legal principle that final judgments must be respected and enforced to ensure justice and stability in the legal system. Parties cannot use the execution phase to relitigate settled issues or delay the implementation of court orders. By upholding the immutability of final judgments, the Supreme Court protects the integrity of the judicial process and ensures that prevailing parties receive the full benefit of their legal victories.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Agdao Landless Residents Association, Inc. vs. Jimmy Eugenio, et al., G.R. No. 224052, December 06, 2021