G.R. No. L-64037 August 27, 1987
PROVINCIAL GOVERNMENT OF SORSOGON, petitioner, vs. ROSA E. VDA. DE VILLAROYA, et. al., GODOFREDO VILLAROYA, et al., AURORA VILLAROYA, et. al., and JUDGE NICOLAS GALING, respondents.

FACTS

The case involves the execution of a final judgment in Civil Case No. 50 for recovery of real property. The then Court of First Instance of Sorsogon declared the private respondents as owners of a 16,500-square-meter lot occupied by Gubat High School. The dispositive portion ordered the Provincial Government of Sorsogon to pay P49,500.00 as the land’s value within one year from receipt of the decision, with the alternative obligation to vacate and deliver the land should it fail to pay. The decision became final, and the petitioner manifested its willingness to pay, even appropriating the amount via a Provincial Board Resolution.
Despite the final judgment and the appropriation, payment was not effected. The Commission on Audit (COA) imposed several pre-payment requirements on the private respondents, including submission of tax documents, deeds of sale, and certificates of fund availability. The private respondents complied, but the COA later imposed an additional, onerous requirement: that the respondents first cause the issuance of a title in the name of the municipality, free from all liens, before payment could be released. This led to a protracted delay spanning years.

ISSUE

Whether the COA, through the Provincial Auditor, can lawfully impose additional requirements, particularly the procurement of a clean title, as a condition for the payment of just compensation mandated by a final and executory judgment.

RULING

The Supreme Court ruled in the negative and ordered the immediate execution of the final judgment. The legal logic is that a final and executory judgment must be executed as mandated, without the addition of substantive conditions that alter its terms. The dispositive portion of the 1974 decision clearly outlined the obligations: the province must pay a specified sum, and upon such payment, the respondents must execute a conveyance. The duty to secure a title free from encumbrances is not imposed on the respondents by the judgment. The COA’s role is to ensure the legality of disbursements, but its audit requirements cannot contravene or unreasonably delay the enforcement of a final judicial decree. The Court found the additional requirement for the respondents to first procure a clean title to be unreasonable, arbitrary, and a distortion of administrative rules that caused unjust vexation. The government, having taken property for public use, has the duty to facilitate the payment of just compensation, not to hinder it with bureaucratic obstacles. Consequently, the Court set aside the lower court’s order upholding the COA’s requirements, reinstated the original judgment, and directed the immediate payment of P49,500.00 with legal interest from 1975, authorizing the seizure of provincial assets if further delays occur.