Prescilla vs. Lasquite

A writ of execution may not issue against persons who were not parties to the prior final judgment, even if such judgment involves the same subject property, where the non-parties' motion for reconsideration of the adverse lower appellate decision remains pending and unresolved, and where the prior judgment did not actually resolve the non-parties' specific claims.

Petitioners Prescilla siblings claimed ownership over Lot 3050 in Barrio Ampid, San Mateo, Rizal based on possession in concepto de dueno since 1940. Respondents Lasquite and Andrade obtained Original Certificates of Title covering the same property in 1981. Victory Hills, Inc. subsequently intervened claiming ownership. The dispute generated multiple appeals and interventions spanning three decades, with the Court of Appeals at one point declaring Victory Hills the owner, only to have that decision reversed by the Supreme Court in a separate proceeding to which petitioners were not parties.

• The Underlying Dispute: Petitioners claimed possession of Lot 3050 in Barrio Ampid, San Mateo, Rizal in concepto de dueno since 1940, planting and cultivating crops thereon. Respondents Lasquite and Andrade obtained Original Certificates of Title (OCT No. NP-198 and OCT No. NP-197) covering the subject property in 1981. Victory Hills, Inc. intervened claiming ownership as successor to prior rights.
• Trial Court Ruling: The RTC upheld respondents' titles over Lot 3050 and petitioners' title over Lot 3052, dismissing the complaints.
• Appellate Proceedings: The CA Eighth Division reversed the RTC, declaring Victory Hills the absolute owner of Lot 3050 and ordering the cancellation of respondents' titles.
• Procedural Divergence: While petitioners filed a Motion for Reconsideration with the CA on November 27, 2006, respondents opted to file a Petition for Review on Certiorari directly with the Supreme Court (G.R. No. 175375) without filing a motion for reconsideration.
• Suspension of Proceedings: The CA Eighth Division issued a Resolution dated December 22, 2006 suspending the resolution of petitioners' Motion for Reconsideration until respondents' appeal to the Supreme Court was resolved with finality.
• Supreme Court Ruling in G.R. No. 175375: The Supreme Court reversed the CA decision and reinstated the RTC decision, finding that Victory Hills failed to show entitlement to reconveyance. The decision became final and executory on February 24, 2010.
• Execution Proceedings: Respondents moved for execution based on the finality of G.R. No. 175375. The RTC granted the motion and issued a Writ of Execution against petitioners.
• Pending Status: As of the resolution of this case, petitioners' Motion for Reconsideration in CA-G.R. CV No. 77599 remained unresolved, having been suspended since 2006.

• Grave Abuse of Discretion: The RTC gravely abused its discretion in issuing a writ of execution against petitioners who were not parties to G.R. No. 175375 and whose motion for reconsideration remained pending before the CA.
• Non-Binding Effect of Prior Judgment: The final judgment in G.R. No. 175375 did not bind petitioners because they were not impleaded therein; a decision binds only parties and their successors-in-interest after the commencement of the action.
• Stay of Execution: Section 4, Rule 52 of the Rules of Court mandates that the pendency of a motion for reconsideration stays execution of the judgment sought to be reconsidered.
• Due Process Violation: Subjecting petitioners to execution without opportunity to appeal violated the constitutional guarantee that no person shall be adversely affected by the outcome of a civil action in which he is not a party.
• Inapplicability of Suson: The CA erred in applying Suson v. Court of Appeals because petitioners had no proper opportunity to intervene in G.R. No. 175375 without committing forum shopping, given the pendency of their motion for reconsideration before the CA.

• Finality of Judgment: The Supreme Court decision in G.R. No. 175375 had become final and executory, reinstating the RTC decision which upheld respondents' ownership over the subject property.
• Identity of Property: The final judgment involved the very same property (Lot 3050) and settled all ownership issues therein, making it binding upon all claimants.
• Opportunity to Be Heard: Petitioners were given their day in court in the proceedings below and had the opportunity to intervene in G.R. No. 175375 but failed to do so.
• Applicability of Suson: Under Suson v. Court of Appeals, execution may issue against non-parties who had the opportunity to intervene in the case involving rights over the same parcel of land but negligently failed to do so.

• Execution Against Non-Parties: Whether the RTC committed grave abuse of discretion in issuing a writ of execution against petitioners who were not parties to G.R. No. 175375.
• Effect of Pending Motion for Reconsideration: Whether execution may issue while petitioners' motion for reconsideration of the adverse CA decision remains pending and unresolved.
• Scope of Prior Judgment: Whether the final judgment in G.R. No. 175375 resolved petitioners' claims of ownership over the subject property.

• Execution Against Non-Parties: Grave abuse of discretion was committed. A judgment of a court is conclusive and binding only upon the parties and their successors-in-interest after the commencement of the action; petitioners were not parties to G.R. No. 175375.
• Effect of Pending Motion for Reconsideration: Execution cannot issue. Section 4, Rule 52 of the Rules of Court provides that the pendency of a motion for reconsideration filed on time and by the proper party shall stay the execution of the judgment or final resolution sought to be reconsidered.
• Scope of Prior Judgment: The judgment in G.R. No. 175375 did not resolve petitioners' claims. The Court therein only determined that Victory Hills failed to prove entitlement to reconveyance; it did not rule on the relative merits of petitioners' claim versus respondents' claim, nor did it resolve that respondents have better rights of ownership compared to petitioners.
• Procedural Anomaly: The CA Eighth Division erred in suspending resolution of petitioners' motion for reconsideration due to co-respondents' appeal; no provision in the Rules of Court mandates or allows appellate courts to suspend the resolution of a party's motion for reconsideration on account of a co-party's appeal to the Supreme Court. This suspension prevented petitioners from exercising their right to appeal.

• Res Judicata and Non-Parties: A judgment of a court is conclusive and binding only upon the parties and their successors-in-interest after the commencement of the action. No person shall be adversely affected by the outcome of a civil action or proceeding in which he is not a party, conforming to the constitutional guarantee of due process.
• Effect of Pending Motion for Reconsideration on Execution: The pendency of a motion for reconsideration filed on time and by the proper party shall stay the execution of the judgment or final resolution sought to be reconsidered (Section 4, Rule 52, Rules of Court).
• Scope of Judicial Determination: A decision that merely resolves one party's claim without adjudicating the competing claims of other parties does not constitute res judicata as to those other parties, even if it involves the same subject matter.
• Improper Suspension of Proceedings: No provision in the Rules of Court mandates or allows appellate courts to suspend the resolution of a party's motion for reconsideration on account of a co-party's appeal to the Supreme Court; the right of one party to file a motion for reconsideration or appeal is not hinged on the motion for reconsideration or appeal of the other party.

• "A decision rendered on a complaint in a civil action or proceeding does not bind or prejudice a person not impleaded therein, for no person shall be adversely affected by the outcome of a civil action or proceeding in which he is not a party. The principle that a person cannot be prejudiced by a ruling rendered in an action or proceeding in which he has not been made a party conforms to the constitutional guarantee of due process of law."
• "The pendency of a motion for reconsideration filed on time and by the proper party shall stay the execution of the judgment or final resolution sought to be reconsidered."
• "Subjecting petitioners Prescilla, et al. to a judgment that they had no opportunity to appeal from due to no fault of their own smacks of violation of due process."

• Lasquite v. Victory Hills, Inc., 608 Phil. 418 (2009) — The prior final judgment reversed by the Court; distinguished because petitioners were not parties thereto and the Court therein only resolved Victory Hills' claim, not petitioners' competing claim.
• Suson v. Court of Appeals, 254 Phil. 66 (1989) — Distinguished; held inapplicable because petitioners had no proper opportunity to intervene in G.R. No. 175375 without committing forum shopping due to the pendency of their motion for reconsideration.
• Muñoz v. Atty. Yabut, Jr., 665 Phil. 488 (2011) — Cited for the principle that a writ of execution can be issued only against a party and not against one who did not have his day in court.
• Guy v. Atty. Gacott, 118 Phil. 308 (2016) — Cited for the principle that a judgment binds only parties and successors-in-interest.

• Section 4, Rule 52, Rules of Court — Provides that the pendency of a motion for reconsideration filed on time and by the proper party shall stay the execution of the judgment or final resolution sought to be reconsidered.
• Rule 1, Section 6, Rules of Court — The objective of the rules of procedure is to secure the just, speedy and inexpensive disposition of every action and proceeding.

Carpio, (Chairperson), J. Reyes, Jr., Lazaro-Javier, and Zalameda, JJ.