The Supreme Court in Lomondot v. Balindong reiterates the principle that a final and executory judgment must be enforced without modification, even if new circumstances are alleged. The Court held that once a decision determining property rights becomes final, it is immutable, and subsequent attempts to alter it, such as ordering a new survey, are invalid. This ruling underscores the importance of respecting final judgments to ensure stability and justice in property disputes. Practically, this means that property owners with court-validated claims can expect those claims to be enforced, preventing endless litigation and protecting their rights from being undermined by delaying tactics or attempts to relitigate settled issues.

When is a Final Decision Really Final? Lomondot’s Fight for Property Rights

The case revolves around a protracted dispute over a parcel of land in Marawi City. Omaira and Saripa Lomondot, the petitioners, filed a complaint in the Shari’a District Court (SDC) in 1991 against Ambog Pangandamun and Simbanatao Diaca, the respondents, for recovery of possession and damages. The Lomondots claimed ownership of an 800-square-meter property, alleging that Pangandamun and Diaca had illegally encroached upon it. The SDC ruled in favor of the Lomondots in 2005, ordering the respondents to vacate the encroached areas and remove any improvements. This decision was appealed but ultimately upheld by the Supreme Court, becoming final and executory.

However, despite the finality of the judgment and the issuance of a writ of execution, the SDC delayed the enforcement of the decision. The respondents claimed that they had already complied with the writ and that their buildings were not within the Lomondots’ property. Based on these claims, the SDC ordered a new survey to determine whether there was indeed an encroachment, effectively suspending the writ of demolition. The Lomondots challenged this order, arguing that it amounted to an impermissible modification of a final judgment. The Supreme Court agreed with the Lomondots, emphasizing the principle of the immutability of final judgments.

The legal framework underpinning the Supreme Court’s decision rests on the doctrine of finality of judgment. This doctrine, as explained in Dacanay v. Yrastorza, Sr., states that once a judgment attains finality, it becomes immutable and unalterable. No modifications are allowed, even if they aim to correct perceived errors of fact or law. This principle is rooted in public policy and ensures that litigation has an end, promoting stability and order in the legal system. The Court noted that allowing the new survey would undermine this principle, as it would effectively reopen a case that had already been conclusively decided.

The respondents argued that a supervening event justified the suspension of the writ of demolition. A supervening event refers to new facts or circumstances that arise after a judgment becomes final and that would make its execution unjust, impossible, or inequitable. However, the Supreme Court rejected this argument, citing Abrigo v. Flores, which clarifies that a supervening event must directly affect the matter already litigated and settled. In this case, the issue of whether the respondents’ houses encroached on the Lomondots’ property had already been decided in the original case. Therefore, their claim of non-encroachment could not be considered a supervening event.

The Supreme Court’s decision also highlights the importance of Section 10(d) of Rule 39 of the Rules of Court, which governs the removal of improvements on property subject to execution. This rule stipulates that while an officer can execute judgments, any improvements made by the judgment obligor cannot be destroyed or removed without a special order from the court. The court issues this order only after a motion by the judgment obligee (in this case, the Lomondots), a due hearing, and a failure by the obligor to remove the improvements within a reasonable time set by the court. The SDC’s failure to issue this special order, despite the Lomondots’ motion and the finality of the judgment, constituted a grave abuse of discretion.

Furthermore, the Court addressed the procedural issue of the Court of Appeals’ (CA) initial dismissal of the case. The CA had reasoned that it lacked jurisdiction over cases originating from Shari’a courts, citing Republic Act No. 9054, which established the Shari’a Appellate Court (SAC). However, the Supreme Court clarified, referencing Tomawis v. Hon. Balindong, that until the SAC is fully organized, appeals or petitions from Shari’a District Courts should be referred to a Special Division within the CA, preferably composed of Muslim CA Justices. Despite this procedural misstep, the Supreme Court opted to resolve the case directly, citing its previous practice of addressing petitions from Shari’a courts.

The implications of this decision are significant for property law and the enforcement of court orders. The Supreme Court’s emphasis on the finality of judgments reinforces the stability of property rights and prevents endless litigation. It sends a clear message that delaying tactics and attempts to relitigate settled issues will not be tolerated. Moreover, the decision underscores the duty of lower courts to faithfully execute final judgments and to avoid actions that effectively modify or nullify them. By ordering the SDC to issue a writ of demolition, the Supreme Court ensured that the Lomondots’ property rights, which had been legally established years earlier, would finally be protected.

FAQs

What was the key issue in this case?	The central issue was whether a Shari’a District Court could delay the execution of a final judgment regarding property rights by ordering a new survey based on claims of non-encroachment. The Supreme Court clarified the principle of finality of judgments and the impermissibility of modifying them.
What is the doctrine of finality of judgment?	The doctrine of finality of judgment states that once a judgment becomes final and executory, it is immutable and unalterable. This means that it cannot be modified in any respect, even if the modification is meant to correct an error of fact or law.
What is a supervening event, and how does it relate to this case?	A supervening event is a fact that transpires after a judgment becomes final and that makes its execution unjust or inequitable. The respondents argued that their claim of non-encroachment was a supervening event, but the Court rejected this because the issue of encroachment had already been decided.
What did the Shari’a District Court initially rule?	The Shari’a District Court initially ruled in favor of the Lomondots, ordering the respondents to vacate the portions of land they had illegally encroached upon. However, the SDC later delayed the execution of this judgment.
Why did the Court of Appeals initially dismiss the case?	The Court of Appeals initially dismissed the case for lack of jurisdiction, believing that cases from Shari’a courts should be handled by the Shari’a Appellate Court. The Supreme Court clarified that until the Shari’a Appellate Court is fully organized, such cases should be referred to a Special Division within the CA.
What is the significance of Section 10(d) of Rule 39 of the Rules of Court?	Section 10(d) of Rule 39 governs the removal of improvements on property subject to execution. It requires a special order from the court before such improvements can be destroyed or removed.
What was the Supreme Court’s final ruling?	The Supreme Court ruled in favor of the Lomondots, ordering the Shari’a District Court to issue a writ of demolition to enforce its original decision. The Court emphasized that the final judgment could not be modified or delayed.
What is the practical implication of this ruling for property owners?	The ruling reinforces the importance of respecting final judgments and ensures that property owners with court-validated claims can expect those claims to be enforced. This prevents endless litigation and protects their rights from being undermined.

In conclusion, the Supreme Court’s decision in Lomondot v. Balindong serves as a strong reminder of the importance of upholding the finality of judgments and protecting property rights. By ordering the enforcement of the original decision, the Court reaffirmed the principle that a final judgment is indeed final and must be respected by all parties involved. This case underscores the need for lower courts to faithfully execute final judgments, preventing endless cycles of litigation and safeguarding the rights of property owners.

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: Lomondot v. Balindong, G.R. No. 192463, July 13, 2015