AM RTJ 99 1433; (June, 2000) (Digest)
March 15, 2026GR 129824; (March, 1999) (Digest)
March 15, 2026G.R. No. 72194; April 5, 1990
THE HEIRS OF CLARO L. LAURETA, petitioners, vs. HON. INTERMEDIATE APPELLATE COURT, MARCOS MATA and CODICI MATA, respondents.
FACTS
This case originated from a 1945 sale of land by Marcos Mata to Claro Laureta. The deed was unacknowledged and unregistered, but Laureta took possession, paid taxes, and made improvements. In 1947, Mata sold the same land to Fermin Caram, Jr., whose deed was registered, leading to the issuance of a new title. Laureta sued for reconveyance. In 1964, the trial court declared Laureta’s prior sale valid, ordered Mata to acknowledge it, and directed the cancellation of Caram’s title. Both Mata and Caram appealed. The Court of Appeals affirmed the decision in 1968. Mata’s separate petition to the Supreme Court (G.R. No. L-29147) was denied and became final in 1968. Caram’s separate petition (G.R. No. L-28740) was decided only in 1981, with finality in 1982. In 1978, the Laureta heirs moved to execute the 1964 judgment against the Mata spouses alone, arguing the judgment against them became final in 1968. The Mata spouses opposed, contending the judgment was indivisible and could only be executed after Caram’s appeal was resolved. The trial court and the Intermediate Appellate Court ruled in favor of the Mata spouses, dismissing the motion for execution as filed beyond the ten-year reglementary period.
ISSUE
Whether the 1964 decision in the reconveyance case constituted a single, indivisible judgment such that its execution could only be sought after all appeals by the different defendants (Mata and Caram) were finally resolved.
RULING
Yes. The Supreme Court reversed the appellate court and dismissed the case, holding that the 1964 judgment was a single, indivisible judgment. The legal logic is that the reliefs granted—declaring Laureta’s sale valid, ordering Mata to acknowledge it, and cancelling Caram’s title—were interdependent and constituted a unified remedy. The cancellation of Caram’s title was a necessary consequence of upholding Laureta’s ownership; these acts could not be separately executed without absurdity. Allowing execution against Mata alone in 1978, while Caram’s title (which derived from Mata) still stood and was under Supreme Court review, would have been legally premature and impermissible. Consequently, the ten-year period for enforcing the judgment commenced only on February 12, 1982, when the decision in Caram’s case (G.R. No. L-28740) became final and executory. Therefore, the Laureta heirs’ motion for execution in 1983 was timely. The ruling emphasizes that a judgment against multiple defendants based on a common cause is generally indivisible, and its finality for execution purposes occurs upon the finality of the last pending appeal.
