This case has been cited 20 times or more.
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2015-08-03 |
BRION, J. |
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| Supervening events, on the other hand, are circumstances that transpire after the decision's finality rendering the execution of the judgment unjust and inequitable.[62] It includes matters that the parties were not aware of prior to or during the trial because such matters were not yet in existence at the time.[63] In such cases, courts are allowed to suspend execution, admit evidence proving the event or circumstance, and grant relief as the new facts and circumstances warrant.[64] | |||||
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2015-06-22 |
REYES, J. |
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| The final and executory nature of the RTC Decision dated April 10, 1990 as against Maricalum is undisputed. Said RTC decision was, in fact, the source of the orders of execution issued by the RTC dated March 9, 2001 and May 10, 2001. Indeed, the well-settled principle of immutability of final judgments demands that once a judgment has become final, the winning party should not, through a mere subterfuge, be deprived of the fruits of the verdict.[29] There are, however, recognized exceptions to the execution as a matter of right of a final and immutable judgment, one of which is the existence of a supervening event.[30] "A supervening event is a fact which transpires or a new circumstance which develops after a judgment has become final and executory. This includes matters which the parties were unaware of prior to or during trial because they were not yet in existence at that time."[31] To be sufficient to stay or stop the execution, a supervening event must create a substantial change in the rights or relations of the parties which would render execution of a final judgment unjust, impossible or inequitable making it imperative to stay immediate execution in the interest of justice.[32] | |||||
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2013-11-13 |
BRION, J. |
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| As a rule, "a final judgment may no longer be altered, amended or modified, even if the alteration, amendment or modification is meant to correct what is perceived to be an erroneous conclusion of fact or law and regardless of what court, be it the highest Court of the land, rendered it. Any attempt on the part of the x x x entities charged with the execution of a final judgment to insert, change or add matters not clearly contemplated in the dispositive portion violates the rule on immutability of judgments."[26]An exception to this rule is the existence of supervening events[27] which refer to facts transpiring after judgment has become final and executory or to new circumstances that developed after the judgment acquired finality, including matters that the parties were not aware of prior to or during the trial as they were not yet in existence at that time.[28] | |||||
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2013-06-17 |
BERSAMIN, J. |
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| We deem it highly relevant to point out that a supervening event is an exception to the execution as a matter of right of a final and immutable judgment rule, only if it directly affects the matter already litigated and settled, or substantially changes the rights or relations of the parties therein as to render the execution unjust, impossible or inequitable.[10] A supervening event consists of facts that transpire after the judgment became final and executory, or of new circumstances that develop after the judgment attained finality, including matters that the parties were not aware of prior to or during the trial because such matters were not yet in existence at that time.[11] In that event, the interested party may properly seek the stay of execution or the quashal of the writ of execution,[12] or he may move the court to modify or alter the judgment in order to harmonize it with justice and the supervening event.[13] The party who alleges a supervening event to stay the execution should necessarily establish the facts by competent evidence; otherwise, it would become all too easy to frustrate the conclusive effects of a final and immutable judgment. | |||||
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2011-12-14 |
PEREZ, J. |
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| Time and again, we have held that once a judgment becomes final and executory, the prevailing party should not be denied the fruits of his victory by some subterfuge devised by the losing party.[39] We completely agree with the RTC's disquisition, thus: Finally, after [MFR] had filed the petition in question pursuant to and in compliance with the order of this court dated September 28, 2004, to which no answer or any responsive pleading was filed by respondents or thru their lawyer, as the latter was certainly notified of the proceedings in said petition, respondents cannot now assail said proceedings after keeping silent thereon for a long time, and if indeed there was neglect on the part of their lawyer in informing them of or in taking part in said proceedings, such negligence of their counsel binds them as client. There is likewise an evident lack of prudence and due diligence on the part of the respondents by their failure to inform this court of the withdrawal of their former counsel for a long period of time, and they cannot now, by feigning ignorance of the proceedings had in the petition in question, assail the same thru a new counsel. In other words, respondents cannot be allowed to keep silent on or refuse to participate in proceedings that they know were taking place in connection with a final judgment rendered against them and then suddenly, after said proceedings were long terminated, come to court to question the same through a new counsel. The respondents are clearly in estoppel. Also, the court finds no practical purpose and benefit in sustaining the theory posited by respondents which, aside from the reasons advanced earlier, will have no other effect than to further unduly delay the execution of a judgment that had long acquired finality.[40] | |||||
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2011-06-08 |
LEONARDO-DE CASTRO, J. |
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| Supervening events refer to facts which transpire after judgment has become final and executory or to new circumstances which developed after the judgment has acquired finality, including matters which the parties were not aware of prior to or during the trial as they were not yet in existence at that time. [86] | |||||
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2010-07-05 |
DEL CASTILLO, J. |
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| The objective of the plaintiffs in accion publiciana is to recover possession only, not ownership.[21] However, where the parties raise the issue of ownership, the courts may pass upon the issue to determine who between the parties has the right to possess the property. This adjudication, however, is not a final and binding determination of the issue of ownership; it is only for the purpose of resolving the issue of possession, where the issue of ownership is inseparably linked to the issue of possession. The adjudication of the issue of ownership, being provisional, is not a bar to an action between the same parties involving title to the property.[22] The adjudication, in short, is not conclusive on the issue of ownership.[23] | |||||
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2009-09-03 |
NACHURA, J. |
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| The purpose of intervention is to enable a stranger to an action to become a party to protect his interest, and the court, incidentally, to settle all conflicting claims.[9] The spouses Vaca are not strangers to the action. Their legal interest in the litigation springs from the sale of the subject property by petitioner in their favor during the pendency of this case. As transferee pendente lite, the spouses Vaca are the successors-in-interest of the transferor, the petitioner, who is already a party to the action. Thus, the applicable provision is Section 19, Rule 3 of the Rules of Court, governing transfers of interest pendente lite. It provides: SEC. 19. Transfer of interest. - In case of any transfer of interest, the action may be continued by or against the original party, unless the court upon motion directs the person to whom the interest is transferred to be substituted in the action or joined with the original party. | |||||
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2009-08-14 |
BRION, J. |
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| The objective of the plaintiffs in accion publiciana is to recover possession only, not ownership.[13] However, where the parties raise the issue of ownership, the courts may pass upon the issue to determine who between or among the parties has the right to possess the property. This adjudication, however, is not a final and binding determination of the issue of ownership; it is only for the purpose of resolving the issue of possession, where the issue of ownership is inseparably linked to the issue of possession. The adjudication of the issue of ownership, being provisional, is not a bar to an action between the same parties involving title to the property.[14] The adjudication, in short, is not conclusive on the issue of ownership.[15] | |||||
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2009-06-16 |
PUNO, J. |
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| It is well-settled that the jurisdiction of the court to execute its judgment continues even after the judgment had become final for the purpose of enforcement of judgment.[10] The present case is no exception. Therefore, notwithstanding the final resolution on the validity of the expropriation made by this Court on June 19, 2003 in G.R. No. 154411, the RTC, Branch 19 can still rule on the motions for the issuance of an alias writ of execution and payment of interest. As the CA correctly stated: "...the duty of the court does not end with the tender of the decision. Equal is the duty of the court to enforce said decision to the fullest of its intent, tenor and mandate. To sustain a contrary view would not only trivialize the decision, but would also render it meaningless; the justice sought by the aggrieved party and supposedly conferred by the court turned inutile."[11] | |||||
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2009-01-19 |
NACHURA, J. |
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| First. The instant case is for accion publiciana, or for recovery of the right to possess. This was a plenary action filed in the regional trial court to determine the better right to possession of realty independently of the title.[18] Accion publiciana is also used to refer to an ejectment suit where the cause of dispossession is not among the grounds for forcible entry and unlawful detainer, or when possession has been lost for more than one year and can no longer be maintained under Rule 70 of the Rules of Court. The objective of the plaintiffs in accion publiciana is to recover possession only, not ownership. [19] | |||||
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2008-11-27 |
CHICO-NAZARIO, J. |
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| A petition for certiorari (as well as one for prohibition) will only prosper if grave abuse of discretion is manifested.[28] The burden is on the part of the petitioner to prove not merely reversible error, but grave abuse of discretion amounting to lack or excess of jurisdiction on the part of the public respondent issuing the impugned order. Mere abuse of discretion is not enough; it must be grave.[29] The term grave abuse of discretion has a technical and set meaning. Grave abuse of discretion is a capricious and whimsical exercise of judgment so patent and gross as to amount to an evasion of a positive duty or a virtual refusal to perform a duty enjoined by law, as where the power is exercised in an arbitrary and despotic manner because of passion or hostility.[30] | |||||
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2007-08-02 |
CORONA, J. |
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| We agree with the OCA that respondent had legal basis in issuing the writ in his March 27, 2000 resolution. It is true that complainants had in their favor a final and executory decision by the MTCC which had become immutable and unalterable.[33] However, one of the exceptions to the principle of immutability of final judgments is the existence of supervening events. Supervening events refer to facts which transpire or new circumstances which develop after the judgment acquires finality, rendering its execution unjust and inequitable.[34] | |||||
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2007-06-26 |
GARCIA, J. |
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| Intervention is a procedure by which a third person, not originally party to the suit, but claiming an interest in the subject matter, comes into the case, in order to protect his right or interpose his claim.[35] Its main purpose is to settle in one action and by a single judgment all conflicting claims of or the whole controversy among the persons involved.[36] To warrant intervention under Rule 19, Section 1 of the Rules of Court,[37] two requisites must concur: (a) the movant has a legal interest in the matter in litigation, and (b) intervention must not unduly delay or prejudice the adjudication of the rights of the parties, nor should the claim of the intervenor be capable of being properly decided in a separate proceeding. The interest, which entitles one to intervene, must involve the matter in litigation and of such direct and immediate character[38] that the intervenor will either gain or lose by the direct legal operation and effect of the judgment.[39] | |||||
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2007-02-28 |
QUISUMBING, J. |
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| Before a judgment becomes final and executory, that judgment may be amended. Upon finality of the judgment, the court loses its jurisdiction to amend, modify or alter the same.[10] Except for correction of clerical errors or the making of nunc pro tunc entries which causes no prejudice to any party, or where the judgment is void, the judgment can neither be amended nor altered after it has become final and executory.[11] This is the principle of immutability of final judgment that is subject only to a few exceptions.[12] None of the exceptions are present in this case. | |||||
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2006-09-19 |
AUSTRIA-MARTINEZ, J. |
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| Verily, by the undue delay in the execution of a final judgment in their favor, respondents have suffered an injustice. The Court views with disfavor the unjustified delay in the enforcement of the final decision and orders in the present case. Once a judgment becomes final and executory, the prevailing party should not be denied the fruits of his victory by some subterfuge devised by the losing party.[78] Unjustified delay in the enforcement of a judgment sets at naught the role of courts in disposing justiciable controversies with finality. | |||||
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2005-11-23 |
AUSTRIA-MARTINEZ, J. |
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| Hence, there can be no other conclusion but that the finality of the decision in the quieting of title case constitutes a supervening event that justifies the non-enforcement of the judgment in the forcible entry case. In Natalia Realty, Inc. vs. Court of Appeals,[11] the Court explained thus:... The jurisdiction of the court to amend, modify or alter its judgment terminates when the judgment becomes final. This is the principle of immutability of final judgment that is subject to only few exceptions, none of which is present in this case. On the other hand, the jurisdiction of the court to execute its judgment continues even after the judgment has become final for the purpose of enforcement of judgment. | |||||
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2005-10-05 |
CORONA, J. |
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| On November 12, 2002, the then First Division of this Court rendered a decision[12] in G.R. No. 126462[13], the dispositive portion of which read: | |||||
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2005-08-25 |
CORONA, J. |
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| Supervening events refer to facts which transpire after judgment becomes final and executory or to new circumstances which develop after judgment acquires finality.[19] The "refusal" of Embang to be reinstated happened, assuming it really happened, before the finality of our September 22, 2003 resolution, i.e., before the decision of the labor arbiter as modified by the NLRC became final and executory. | |||||
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2005-04-22 |
CORONA, J. |
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| Petitioners' act of filing their motion to suspend execution/period of compliance by reason of supervening events also showed their continuing, stubborn resistance to this Court's judgment. Indeed, one of the exceptions to the principle of immutability of final judgments is the existence of supervening events. Supervening events refer to facts which transpire after judgment has become final and executory or to new circumstances which develop after the judgment has acquired finality.[17] | |||||