Eternal Gardens Memorial Park Corporation vs. Court of Appeals

A transferee pendente lite is bound by the judgment against the transferor without needing to be impleaded, and the execution of a final judgment cannot be stayed by the pendency of a subsequent action that cannot validate the annulled title of the judgment debtor. The Court held that because petitioner acquired the property from the defendant during the pendency of the case, it was bound by the judgment nullifying the defendant's title; moreover, because the writs of execution had already been satisfied, the petition was moot.

Private respondents Spouses Seelin filed a complaint for quieting of title and nullification of Transfer Certificate of Title (TCT) No. 205942 against Central Dyeing & Finishing Corporation. The Regional Trial Court of Caloocan City nullified the title, a decision affirmed by the Court of Appeals and the Supreme Court. Central Dyeing had sold the property to petitioner Eternal Gardens Memorial Park Corporation, which developed the land into a memorial park and sold burial lots to over a hundred individuals. When private respondents sought execution of the final judgment to recover possession, petitioner opposed, claiming it was a buyer in good faith and not a party to the original case.

• Origin of the Dispute: Spouses Seelin filed a case against Central Dyeing to nullify TCT No. 205942.
• RTC Decision: Nullified the title.
• Acquisition by Petitioner: Eternal Gardens bought the property from Central Dyeing and developed it into a memorial park, selling burial lots to over 100 individuals.
• Execution Phase: After the judgment became final and executory, private respondents sought execution and a writ of possession. Petitioner opposed, claiming it was not a party to the original case, was a buyer in good faith, and that execution would desecrate graves and violate freedom of religion.
• Subsequent Developments: The Republic of the Philippines filed a separate case (Civil Case No. C-11337) against private respondents for nullification of 22 titles, including the subject title.
• Full Satisfaction: The alias writs of execution and possession were fully implemented by the Deputy Sheriff, who turned over the premises to private respondents on March 31, 1995.

• Petitioner argued that the judgment could not be executed against it because it was not a party to Civil Case No. C-9297.
• Petitioner maintained that the trial court decision never mandated Central Dyeing to deliver possession of the property to private respondents.
• Petitioner contended that circumstances transpiring after the finality of judgment—specifically, the pendency of Civil Case No. C-11337 filed by the Republic for nullification of private respondents' titles—rendered the execution unjust, illegal, and inequitable.
• Petitioner asserted that the issuance of the writ of execution violated the burial lot buyers' freedom of religion and worship.
• Petitioner claimed that private respondents' title was being questioned in another case.

• Respondents countered that petitioner was bound by the decision as a transferee pendente lite under Section 20, Rule 3 of the Revised Rules of Court.
• Respondents argued that a separate action for possession was unnecessary because possession was the logical consequence of the judgment declaring them the rightful owners.
• Respondents maintained that the petition was a mere dilatory tactic to prevent them from benefiting from a final judgment.
• Respondents pointed out that the petition had become moot and academic because the property had already been turned over to them by the Deputy Sheriff.

• Procedural Issues: Whether the petition has been rendered moot and academic by the full implementation of the writs of execution and possession.
• Substantive Issues: Whether a transferee pendente lite can be bound by a judgment in a case where it was not impleaded. Whether a separate action for possession is necessary before a writ of possession can be issued to the prevailing party declared the rightful owner. Whether the pendency of a subsequent case for nullification of the prevailing party's title justifies the suspension of the execution of a final judgment.

• Procedural: The Court ruled that the petition was rendered moot and academic because the alias writs of execution and possession had already been fully implemented and the property turned over to private respondents, as shown by the Sheriff's Return dated March 31, 1995.
• Substantive: The Court held that under Section 20, Rule 3 of the Revised Rules of Court, a transferee pendente lite does not have to be impleaded to be bound by the judgment; the action may continue against the original party and the judgment remains binding on the transferee. Because petitioner admitted buying the property from Central Dyeing, it was bound by the judgment nullifying Central Dyeing's title. The Court ruled that a separate action for possession is unnecessary, because placing the owners in possession is the necessary and logical consequence of a decision declaring them the rightful owners. The Court held that the pendency of a subsequent case for annulment of the prevailing party's title does not justify staying execution, because even if that title is nullified, it cannot validate the petitioner's already-annulled title or make petitioner the rightful owner.

• Transferee Pendente Lite Doctrine — Under Section 20, Rule 3 of the Revised Rules of Court, a transferee pendente lite does not have to be included or impleaded by name in order to be bound by the judgment; the action or suit may be continued for or against the original party or the transferor and still be binding on the transferee. The Court applied this to hold petitioner bound by the judgment against Central Dyeing, from whom petitioner bought the property.
• Finality of Judgments — Once a judgment becomes final and executory, all the issues between the parties are deemed resolved, and courts must guard against any scheme to prolong the litigation or deprive the winning party of the fruits of the verdict. The Court emphasized this to denounce petitioner's dilatory tactics over 17 years.
• Mootness — A case becomes moot and academic when the writs challenged have already been implemented and fully satisfied, leaving no practical relief that the Court can grant. The Court found the petition moot based on the Sheriff's Return indicating the turnover of the property to private respondents.

• "Under Section 20, Rule 3, Revised Rules of Court, a transferee pendente lite does not have to be included or impleaded by name in order to be bound by the judgment because the action or suit may be continued for or against the original party or the transferor and still be binding on the transferee." — Defines the binding effect of judgments on pendente lite transferees.
• "Placing private respondents in possession of the land in question is the necessary and logical effect or consequence of the decision in Civil Case No. C-9297 declaring them as the rightful owners of the property." — Explains why a separate action for possession is unnecessary after a declaration of ownership.
• "litigations must end and terminate sometime and somewhere, it being essential to the effective administration of justice that once a judgment has become final, the winning party be not, through a mere subterfuge, deprived of the fruits of the verdict." — Underscores the principle of immutability of final judgments.

• Gomez vs. Presiding Judge, RTC, Br. 15, Ozamis City, 249 SCRA 438 (1995) — Cited as controlling precedent for the doctrine that litigations must end and courts should frown upon attempts to prolong them and deprive the winning party of the verdict's fruits.
• Banogan et. al. vs. Cerna, et. al., 154 SCRA 593 — Followed for the principle that lawyers, as officers of the court, have a responsibility to assist in the proper administration of justice and should not file pointless, dilatory petitions that clutter the dockets.

• Section 20, Rule 3, Revised Rules of Court — Provides that when a party transfers interest during the pendency of the action, the action may be continued by or against the original party, and the judgment is binding on the transferee. Applied to bind petitioner, who bought the property from the original defendant.
• Rule 39, Section 48(b), Revised Rules of Court — Cited by the trial court regarding judgments binding on successors-in-interest.
• Section 3, Rule 142, Revised Rules of Court — Mentioned by the CA regarding the assessment of double costs against petitioner for filing a frivolous and dilatory petition.

Regalado, Melo, Puno, and Mendoza, JJ.