Urduja Ortiz-Aquino vs. Letecia Ortillo, et al.

Once a judgment attains finality, execution is a matter of right for the winning party and a ministerial duty of the court; the family home exemption under the Family Code applies only to money judgments and only where the family home is constituted on property owned by the person claiming the exemption, and the claim must be set up and proved by evidence.

Alfonso P. Ortillo, Jr., predecessor-in-interest of respondents Letecia and Lisette Ortillo, owned a parcel of land in Barangay Baybay, Aguilar, Pangasinan, covered by Tax Declaration No. 1735 and containing about 8,760 square meters. Felicidad Ortiz, predecessor-in-interest of petitioner Urduja Ortiz-Aquino, was the prospective buyer under an April 30, 1994 Agreement over a portion of that property. The Family Code provisions on the family home—Articles 152, 155, 156, 157, and 160—provide the statutory backdrop for the exemption issue later raised during execution.

On April 30, 1994, Alfonso P. Ortillo, Jr., who owned a portion of a parcel of land in Barangay Baybay, Aguilar, Pangasinan covered by Tax Declaration No. 1735 and containing about 8,760 square meters, entered into an Agreement with Felicidad Ortiz. Under the Agreement, Felicidad agreed to buy the property at PHP 55.00 per square meter, or a total of PHP 481,800.00, and Alfonso acknowledged receipt of PHP 5,000.00. Felicidad thereafter made installment payments from 1994 to 2001 totaling PHP 73,500.00, but she did not pay the full purchase price.

On March 28, 2012, Urduja and her family, through their counsel Atty. Corleto R. Castro, sent a letter to respondents about the sale of the subject property to Felicidad. The letter requested a meeting among the parties so that the sale could be completed, but the request was unheeded and the balance of the purchase price remained unpaid. Sometime around June 2012, respondents filed with the RTC a Complaint for Quieting of Title and Recovery of Possession, docketed as Civil Case No. 19191.

In their Answer, Urduja and her co-defendants admitted that Alfonso and Felicidad executed the Agreement, that the purchase price was payable in installments, and that Felicidad failed to pay the full purchase price. They claimed, however, that they were not claiming the entire 8,760 square meters but only the 3,745-square-meter portion they occupied; they asserted ownership of that portion because Alfonso allowed them to possess it after the Agreement. They admitted that they had not fully paid the price for the 3,745-square-meter portion at PHP 55.00 per square meter, or PHP 205,975.00, but expressed willingness to pay the remaining balance of PHP 132,475.00 after crediting prior installment payments.

The RTC declared the Agreement a contract to sell. It relied on the tenor of the Agreement, in which Felicidad merely "agreed to buy"; on the letter, which showed that the proposed meeting was to complete the sale; and on the fact that the contract was embodied in a document other than a deed of sale. Because Felicidad did not pay the full purchase price, the RTC concluded that the contract to sell was terminated or cancelled and that ownership of the subject property remained with respondents. It directed Urduja and her co-defendants to surrender possession of the subject property to respondents and ordered respondents to return PHP 52,500.00 to them.

Urduja and her co-defendants appealed the RTC Decision, but the CA dismissed the appeal under Section 1(h), Rule 50 of the Rules of Court, and the dismissal became final and executory on May 2, 2017. On September 10, 2018, respondents filed a Motion for Execution. Urduja filed a Motion to Hold in Abeyance, claiming that their family home was situated on the subject property and that she had been unaware of the dismissal of the appeal until she received the RTC Order dated November 5, 2018; she also discovered that her previous counsel, Atty. Castro, had been sickly during the appeal and had since died. The RTC granted execution on January 15, 2019, and denied reconsideration on July 8, 2019, ruling that a family home may only be constituted on property owned by the persons constituting it. When the Sheriff scheduled respondents' payment of the PHP 52,500.00 on March 20, 2019, Urduja and her co-defendants refused to receive the money; respondents remitted it to the Sheriff, who turned it over to the RTC. The RTC found that ownership remained with respondents and that Urduja failed to present evidence supporting her family home claim.

• Settlement / Abeyance of Execution: Petitioner argued that execution of the final RTC Decision dated October 21, 2015 should be held in abeyance so that the parties may seek avenues for settlement.
• Family Home Exemption: Petitioner maintained that her family home, erected on the subject property, is exempt from execution.
• Due Process: Petitioner argued that she and her family were denied due process because of "peculiar circumstances," referring to the dismissal of their appeal and the death of their previous counsel, Atty. Castro.
• Absence of Ownership Finding: Petitioner contended that execution should be held in abeyance because the RTC never made any express finding that the subject property is owned by respondents.
• Nonpayment of PHP 52,500.00: Petitioner argued that execution is improper because the PHP 52,500.00 due from respondents under the RTC Decision has not yet been satisfied.
• Injunctive Relief: Petitioner prayed for a temporary restraining order and/or writ of preliminary injunction pending resolution of the case.

• Belated Family Home Claim: Respondents argued that petitioner's allegations regarding her supposed family home were belatedly raised and intended only to thwart execution of the final and executory RTC Decision, especially since she failed to present evidence during the hearing on the Motion for Execution.
• Improper Forum for Ownership Issue: Respondents averred that the issue of ownership of the subject property should have been ventilated in Civil Case No. 19191 and the appeal therefrom, not in the present proceedings, which must be limited to the propriety of execution.
• Estoppel / Recognition of Alfonso's Ownership: Respondents added that petitioner is estopped from assailing respondents' ownership because petitioner's predecessor-in-interest, Felicidad, recognized Alfonso's ownership of the subject property in the Agreement.
• Denial of Petition: Respondents prayed for denial of the Petition.

• Grave Abuse of Discretion / Execution of Final Judgment: Whether the CA erred in not finding grave abuse of discretion on the part of the RTC when it directed the execution of its Decision dated October 21, 2015, which had attained finality.
• Family Home Exemption: Whether petitioner's alleged family home is exempt from execution.
• Due Process: Whether petitioner and her family were denied due process because of the dismissal of their appeal and the death of their previous counsel.
• Ownership Finding: Whether execution was improper because the RTC made no express finding that respondents own the subject property.
• Nonpayment of PHP 52,500.00: Whether execution was improper because respondents had not yet paid the PHP 52,500.00 due under the RTC Decision.
• Injunctive Relief: Whether petitioner is entitled to a temporary restraining order and/or writ of preliminary injunction.

• Grave Abuse of Discretion / Execution of Final Judgment: No. The RTC did not gravely abuse its discretion; execution of a final and executory judgment is a matter of right for the winning party and a ministerial duty of the court.
• Family Home Exemption: No. The exemption applies to money judgments, and a family home must be constituted on property owned by the person claiming it; petitioner also failed to prove the requisites by evidence.
• Due Process: No. Petitioner actively participated in the RTC proceedings and had the opportunity to present evidence; the negligence of her counsel binds her absent extraordinary circumstances.
• Ownership Finding: No. The RTC expressly adjudicated ownership in favor of respondents, and the final and executory decision can no longer be disturbed.
• Nonpayment of PHP 52,500.00: No. Petitioner refused to receive the amount; compliance with a court order is not for the parties to decide.
• Injunctive Relief: No. The Petition lacks merit, and no court should interfere with the execution of a final judgment.

• Grave Abuse of Discretion / Execution of Final Judgment: The CA correctly ruled that the RTC did not act with grave abuse of discretion. Once a judgment becomes final and executory, all issues between the parties are deemed resolved and laid to rest, and no other action can be taken except to order its execution. Execution is a matter of right for the winning party and a ministerial duty of the court. The RTC Decision became final and executory on May 2, 2017; respondents acquired vested rights and were entitled to execution. Undue delay in execution is disfavored. While final judgments may be assailed for fraud, lack of jurisdiction, or irregularity apparent on the face of the decision, petitioner did not establish any of these exceptions. She did not contest that the RTC Decision had attained finality. Thus, the validity and execution of the final decision could no longer be assailed.

• Family Home Exemption: The claim lacks support in law, jurisprudence, and evidence. Under Articles 155, 157, and 160 of the Family Code, the family home is exempt from execution, forced sale, or attachment for the satisfaction of money judgments or pecuniary obligations. The RTC Decision did not award a money judgment in favor of respondents; it declared that Alfonso's obligation to sell never arose because Felicidad failed to pay the full purchase price, retained ownership in respondents, and ordered petitioner and her co-defendants to surrender possession. The writ of execution commanded surrender of possession, not sale of property to satisfy a money judgment. There was no levy, forced sale, or attachment against the alleged family home. Moreover, under Articles 152 and 156, a family home consists of the dwelling house and the land on which it is situated, and it must be constituted on property owned by the persons constituting it. The subject property was owned by respondents as finally adjudged. The second paragraph of Article 156, allowing property under a conditional sale on installments to be constituted as a family home, does not apply because it contemplates eventual ownership, not ownership by another. Execution may only be effected against property owned by the judgment debtor. Petitioner also failed to prove the requisites for exemption; her Motion to Hold in Abeyance contained no supporting evidence, and she presented none during the hearing on execution.

• Due Process: The essence of due process is the opportunity to be heard and to submit evidence in support of one's claims or defenses. Due process is served as long as the party was able to present evidence at some point in the proceedings, even if the party was not able to fully exhaust all available remedies, as when an appeal is lost because counsel failed to file the necessary notice of appeal or brief. Petitioner and her co-defendants actively participated in the trial before the RTC, submitted responsive pleadings, and presented evidence, which the RTC considered in rendering its Decision. The dismissal of their appeal did not deprive them of due process. The general rule is that the mistake or negligence of counsel binds the client absent extraordinary circumstances. Petitioner waited about three years after the RTC Decision and about one and a half years after the dismissal of the appeal before learning of the dismissal. No justification was offered, such as indigency, malicious deprivation of information, or inability to act with ordinary diligence. Thus, petitioner was bound by counsel's negligence.

• Ownership Finding: The argument that the RTC made no express finding of ownership is contradicted by the record. The RTC categorically adjudicated ownership in favor of respondents, stating that ownership over the subject property still remained with respondents. This was based on the RTC's finding that the Agreement was a contract to sell that was cancelled or terminated because Felicidad failed to pay the full purchase price. The RTC Decision and its determination of ownership had become final and executory and could no longer be disturbed. Petitioner's plea to revisit ownership was therefore denied. Further, any claim for the value of improvements or the constitution of a family home should have been pleaded in the Answer to the Complaint in Civil Case No. 19191 because it was necessarily connected with the Agreement; having failed to raise it at the earliest instance, petitioner was barred from litigating it after finality.

• Nonpayment of PHP 52,500.00: The argument that execution should be held in abeyance because respondents had not paid the PHP 52,500.00 is without merit. The Sheriff's Report stated that on March 20, 2019, petitioner and her co-defendants refused to receive the amount; respondents then remitted it to the Sheriff, who turned it over to the RTC. The Court cannot enjoin execution on this ground, as it would reward petitioner's unjustified refusal to comply with a lawful order and writ of execution. Compliance with a court order is not for the parties to decide simply because they believe it invalid.

• Injunctive Relief: Because the Petition lacks merit, the prayer for a temporary restraining order and/or writ of preliminary injunction must also be denied. No court, by injunction or otherwise, should interfere with the execution of a final judgment. The RTC Decision had already determined with finality that respondents' right over the subject property, as owners, is superior to any purported entitlement of petitioner and her co-defendants.

• Immutability of Final Judgments / Finality of Judgment — Once a judgment becomes final and executory, all issues between the parties are deemed resolved and laid to rest, and no other action can be taken except to order its execution. Execution is a matter of right for the winning party and a ministerial duty of the court. The recognized exceptions are fraud, lack of jurisdiction, or irregularity apparent on the face of the decision. In this case, the RTC Decision became final and executory on May 2, 2017, petitioner did not contest finality, and none of the exceptions was established; the RTC was therefore duty-bound to order execution.

• Family Home Exemption Limited to Money Judgments — Under Articles 155, 157, and 160 of the Family Code, the family home is exempt from execution, forced sale, or attachment for the satisfaction of money judgments or pecuniary obligations. The exemption protects the family home from being sold to obtain money to satisfy a monetary debt. It does not apply where the judgment does not award a money judgment but instead declares ownership and orders recovery of possession. Here, the RTC Decision ordered petitioner and her co-defendants to surrender possession of the subject property; it did not order a levy or execution sale to satisfy a money judgment.

• Requisites for Family Home Exemption — A claim that a property is a family home immune from levy must be set up and proved by evidence showing that the dwelling house and the land on which it is situated: (i) were duly constituted as a family home; (ii) were constituted jointly by the husband and wife or by an unmarried head of a family; (iii) were resided in by the family or any of the family home's beneficiaries; (iv) form part of the properties of the absolute community or the conjugal partnership, or of the exclusive properties of either spouse with the latter's consent, or property of the unmarried head of the family; and (v) have an actual value of PHP 300,000.00 in urban areas and PHP 200,000.00 in rural areas. The absence of any element results in denial of the exemption. Petitioner failed to prove these requisites, especially the ownership element, and presented no evidence in her Motion to Hold in Abeyance or at the hearing.

• Family Home Must Be Constituted on Owned Property — Article 152 of the Family Code defines the family home as the dwelling house where the family resides and the land on which it is situated. Article 156 requires that the family home be part of the properties of the absolute community or conjugal partnership, or of the exclusive properties of either spouse with the latter's consent, or the property of an unmarried head of a family. A family home may only be constituted on a house and lot owned by the persons constituting it. The second paragraph of Article 156, allowing property subject to a conditional sale on installments where ownership is reserved by the vendor to be constituted as a family home, contemplates eventual ownership by the buyer; it does not permit a family home on property owned by another. Here, the subject property was owned by respondents as finally adjudged, so petitioner could not validly constitute a family home on it.

• Due Process and Negligence of Counsel — The essence of due process is the opportunity to be heard and to submit evidence in support of one's claims or defenses. Due process is not denied where the party was able to participate in trial and present evidence, even if the appeal was later dismissed because of counsel's failure to comply with court orders or file the required brief. The general rule is that the mistake or negligence of counsel binds the client, absent extraordinary circumstances such as indigency, malicious deprivation of information, or inability to act to protect one's interests despite ordinary diligence. Petitioner actively participated in the RTC proceedings, and no extraordinary circumstance excused her failure to monitor her appeal for almost three years.

• Execution Only Against Property of the Judgment Debtor — Execution may be effected only against property owned by the judgment debtor. The family home exemption extends only to the owners of the house and lot constituting the family home. A contrary rule would allow execution against property of third persons who did not have their day in court. Since the subject property was owned by respondents, not petitioner, the exemption could not be claimed against it.

• Improvements or Family Home Claim Must Be Pleaded in Answer — In an action for recovery of a parcel of land, the defendant must set up a counterclaim for the value of improvements made or introduced on the property because such claim is necessarily connected with the transaction or occurrence subject of the complaint. A claim for payment of the value of improvements after final judgment must be denied because it would modify a final judgment and violate its immutability. By analogy, petitioner should have pleaded the alleged constitution of her family home in her Answer in Civil Case No. 19191; having failed to do so and to present supporting evidence, she was barred from raising it during execution.

• No Interference with Execution of Final Judgment — No court, by injunction or otherwise, should interfere with the execution of a final judgment. The general rule admits exceptions, such as when facts and circumstances later transpire that would render execution inequitable or unjust, or when there is a change in the situation of the parties that may warrant injunctive relief. No such exception was shown; the RTC Decision had determined with finality that respondents' right as owners was superior to petitioner's purported entitlement.

• "It is well-established that once a judgment becomes final and executory, all the issues between the parties are deemed resolved and laid to rest, and no other action can be taken thereon except to order its execution, which is a matter of right for the winning party." — This passage states the ratio decidendi on finality and execution, grounding the Court's holding that the RTC had no discretion to delay execution of the final Decision.
• "The claim that a property is a family home that is immune from levy is not a magic wand that will freeze the court's hand to forestall the execution of a decision that has attained finality." — This formulation emphasizes that a family home claim must be substantiated and cannot by itself bar execution of a final judgment.
• "The absence of any of the foregoing elements results in the denial of a claim of exemption of the alleged family home from execution." — This passage states the consequence of failing to prove the requisites for family home exemption, which the Court applied against petitioner.
• "In fine, Urduja, et al. are bound by the negligence of their counsel and the resultant loss of their appeal because they failed to diligently check on the status of their case." — This passage encapsulates the due process ruling: clients are generally bound by counsel's negligence absent extraordinary circumstances, and petitioner's failure to monitor her appeal was fatal.

• Sps. Poblete vs. Banco Filipino Savings and Mortgage Bank, 874 Phil. 112, 120-121 (2020); NAPOCOR vs. Sps. Laohoo, 611 Phil. 194, 209 (2009) — Cited for the rule that once a judgment becomes final and executory, no other action can be taken except to order its execution.
• Frias vs. Alcayde, 826 Phil. 713, 744 (2018); Manila Memorial Park Cemetery, Inc. vs. Court of Appeals, 398 Phil. 720, 729-730 (2000) — Cited to support the principle that the winning party acquires a vested right to execution as a matter of right.
• Montehermoso vs. Batuto, 891 Phil. 532, 534-535 (2020), citing Spouses Aguilar vs. Manila Banking Corp., 533 Phil. 645, 670 (2006) — Cited for the rule that undue delay in the execution of a final judgment is greatly disfavored.
• Cadano vs. Cadano, 151 Phil. 156, 166 (1973); Vda. de Corpuz vs. The Commanding General, Phil. Army, 174 Phil. 689, 698 (1978) — Cited for the exceptions to finality: lack of jurisdiction, irregularity apparent on the face of the record, or fraud.
• Baclayon vs. Court of Appeals, 261 Phil. 910, 922 (1990); Carpena vs. Manalo, 111 Phil. 685, 688 (1961), citing Berses vs. Villanueva, 25 Phil. 473, 488-489 (1913) — Cited for the rule that a defendant in a land recovery case must set up a counterclaim for improvements; a later claim would modify a final judgment.
• Pasiona, Jr. vs. Court of Appeals, 581 Phil. 124, 135 (2008), citing Producers Bank of the Phils. vs. Court of Appeals, 430 Phil. 812, 825-826 (2002) — Cited for the essence of due process as the opportunity to be heard and submit evidence.
• Sibayan vs. Costales, 789 Phil. 1, 7-8 (2016) — Cited for the rule that due process is not denied where the party actively participated in trial despite dismissal of appeal for counsel's failure to file the required brief.
• Engr. Paluca vs. Commission on Audit, 788 Phil. 483, 490 (2016); Oriental Assurance Corp. vs. Solidbank Corp., 392 Phil. 847, 856-857 (2000) — Cited for the general rule that the negligence of counsel binds the client and for the need to show the client's own diligence.
• Lasala vs. National Food Authority, 767 Phil. 285, 302-303 (2015), citing Bayog vs. Natino, 327 Phil. 1019 (1996) — Cited to illustrate an exception to the counsel-negligence rule, as where the litigant is an indigent and solely relies on counsel.
• Cabang vs. Spouses Basay, 601 Phil. 167, 178 (2009) — Cited for the definition of the family home as the dwelling house and the land on which it is situated.
• Taruc vs. Maximo, G.R. No. 227728, September 28, 2022 — Cited for the requisites of family home exemption and the rule that absence of any requisite denies the claim.
• Montoya vs. Ignacio, 102 Phil. 546, 547-549 (1957); Siari Valley Estates, Inc. vs. Lucasan, 109 Phil. 294, 298-299 (1960) — Cited for the rule that the family home exemption is tied to the satisfaction of money judgments or pecuniary obligations.
• De Guzman vs. Spouses Ong, 363 Phil. 548, 555 (1999); Alvaran vs. Marquez, 11 Phil. 263, 267 (1908); Guy vs. Gacott, 778 Phil. 308, 321 (2016) — Cited for the rule that execution may be effected only against property of the judgment debtor, not against property of third persons.
• Salazar vs. Felias, 825 Phil. 30, 42 (2018); Spouses Versola vs. Court of Appeals, 529 Phil. 377, 387 (2006) — Cited for the requirement that a claim of exemption from execution must be supported by evidence.
• Australian Professional Realty, Inc. vs. Municipality of Padre Garcia, Batangas, 684 Phil. 283, 294 (2012) — Cited for the rule that after finality, execution is ministerial, subject only to exceptions such as later inequitable circumstances or changed situation.
• Bro. Bernard Oca vs. Custodio, 814 Phil. 641, 675 (2017) — Cited for the principle that compliance with a court order is not for the parties to decide based on their own view of its validity.
• Chua vs. Court of Appeals, 449 Phil. 25 (2003) — Cited by the RTC in concluding that the Agreement was a contract to sell, not a deed of sale.
• Taneo, Jr. vs. Court of Appeals, 363 Phil. 652 (1999) — Cited by the RTC in ruling that a family home may only be constituted on property owned by the persons constituting it.
• Wolf vs. Fleischacker, 5 Cal. 244 (Cal. 1855); People vs. Pagpaguitan, 373 Phil. 856, 872 (1999) — Cited as persuasive foreign jurisprudence explaining why a family home cannot be created on property held with third persons, and for the rule that foreign decisions construing a copied rule are entitled to great weight.
• UCPB General Insurance Co., Inc. vs. Hughes Electronics Corp., 800 Phil. 67, 80 (2016) — Cited for the meaning of "may" as connoting opportunity or possibility, in interpreting Article 156 of the Family Code.
• Solid Homes, Inc. vs. Sps. Jurado, 861 Phil. 36, 62 (2019); Heirs of Paulino Atienza vs. Espidol, 642 Phil. 408, 417-419 (2010) — Cited for the rule that installment payments in a cancelled contract to sell should be returned or reimbursed absent stipulation to the contrary.
• E. Rommel Realty and Development Corporation vs. Sta. Lucia Development Corporation, 537 Phil. 822, 831 (2006); Sama vs. People, G.R. No. 224469, January 5, 2021 — Cited for the attribute of ownership that includes the right to possess and exclude others.
• Morales vs. Arboleda, G.R. No. 211322 (Notice), March 18, 2015; Corinthian Gardens Ass'n, Inc. vs. Spouses Tanjangco, 178 Phil. 712 (2008); Pasion vs. Melegrito, 548 Phil. 302 (2007) — Cited for the rule that no court should interfere with execution of a final judgment and that respondents' superior right as owners was settled.
• Eulogio vs. Bell, 763 Phil. 266, 283 (2015); Sia vs. Tan, G.R. No. 220695 (Notice), January 5, 2022 — Cited for the policy favoring conservation of the family home and related immunities.
• People vs. Chaves, 120 Phil. 1019, 1022 (1964); Yuzon vs. Atty. Agleron, 824 Phil. 321, 326 (2018) — Cited for the definition of "levy" and the humane considerations behind family home immunities.
• Guevarra vs. Sps. Bautista, 593 Phil. 20, 26 (2008); Ong Lay Hin vs. Court of Appeals, 752 Phil. 15, 25 (2015) — Cited for the rule that grounds for relief from judgment and exceptions to counsel negligence must be established by the petitioner.
• Baclaran Marketing Corporation vs. Nieva, 809 Phil. 92, 104 (2017) — Cited for the rule that gross negligence of counsel must not be accompanied by the client's own negligence for the client to be excepted from the counsel-negligence rule.
• Honrado vs. Court of Appeals, 512 Phil. 657, 666 (2005); Sps. Oliva-De Mesa vs. Sps. Acero, Jr., 679 Phil. 43, 59 (2012) — Cited for the evidentiary requirement in claims of exemption from execution.

• Article 152, Family Code — Defines the family home as the dwelling house where the family resides and the land on which it is situated; the Court used this definition to hold that both the house and lot must be owned by the persons constituting the family home.
• Article 155, Family Code — Exempts the family home from execution, forced sale, or attachment except for specified debts; the Court held that this exemption is limited to the satisfaction of money judgments or pecuniary obligations.
• Article 156, Family Code — Requires the family home to be part of the properties of the absolute community or conjugal partnership, or of the exclusive properties of either spouse with the latter's consent, or the property of an unmarried head of a family; the second paragraph allows property subject to a conditional sale on installments to be constituted as a family home, but the Court held this contemplates eventual ownership by the buyer, not property owned by another.
• Article 157, Family Code — Sets the maximum actual value of the family home at PHP 300,000.00 in urban areas and PHP 200,000.00 in rural areas; the Court cited this to show that the exemption is tied to a monetary limit and to money judgments.
• Article 158, Family Code — Imposes restrictions on the sale, alienation, donation, assignment, or encumbrance of the family home with the written consent of the persons constituting it; the Court cited this to illustrate why a family home cannot be constituted on property owned by third persons.
• Article 159, Family Code — Provides for the continuation of the family home despite the death of one or both spouses or the unmarried head of the family and restricts partition by heirs; the Court cited this in the same discussion on the limitations that cannot be imposed on third-party property.
• Article 160, Family Code — Allows a creditor to apply for the sale of a family home whose actual value exceeds the maximum fixed in Article 157; the Court cited this to reinforce that the family home exemption operates in relation to money judgments or debts.
• Section 1(h), Rule 50, Rules of Court — An appeal may be dismissed by the Court of Appeals for failure of the appellant to comply with orders, circulars, or directives of the court without justifiable cause; the CA dismissed Urduja, et al.'s appeal under this provision.
• Rule 45, Rules of Court — The instant Petition was filed as a Petition for Review on Certiorari under Rule 45.
• Rule 65, Rules of Court — Urduja filed a Petition for Certiorari with the CA under Rule 65 assailing the RTC Resolutions dated January 15, 2019 and July 8, 2019.

Caguioa, Acting Chief Justice (Chairperson); Gaerlan; Dimaampao; and Singh.