G.R. No. 176533 ; February 11, 2008
JEROME SOLCO, petitioner, vs. CLAUDINA V. PROVIDO and MARIA TERESA P. VILLARUEL, respondents.

FACTS

The parties entered into a Contract to Sell over a parcel of land. Petitioner Jerome Solco paid the initial amount, but respondents, the Villaruels, filed a complaint for rescission alleging breach. The trial court dismissed the complaint and ordered the Villaruels to clear the property, vacate it, and restore possession to Solco. It also ordered Solco to pay the balance of the purchase price, less awarded damages, upon the expiration of a 30-day period for the Villaruels to comply. This decision was affirmed with modifications by the Court of Appeals and became final. Upon execution, the sheriff found the property vacated except for a billboard. The sheriff then demanded that Solco pay the balance. Solco later tendered payment via a cashier’s check, but the Villaruels refused it, arguing the tender was late and the billboard issue remained. The trial court accepted Solco’s payment and ordered the execution of a deed of sale. The Villaruels filed a separate action for annulment and appealed the trial court’s orders, which the Court of Appeals reversed.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s orders which accepted Solco’s payment and compelled the execution of the deed of absolute sale.

RULING

Yes, the Court of Appeals erred. The Supreme Court reinstated the trial court’s orders. The legal logic centers on the execution of a final judgment. The decision had become final and executory; its terms were clear and constituted the law between the parties. The judgment ordered Solco to pay the balance upon the expiration of the 30-day period given to the Villaruels to clear the property. The sheriff’s finding that the property was vacated (with the billboard being a minor, non-obstructive item) signified substantial compliance by the Villaruels, triggering Solco’s obligation to pay. His subsequent tender of a cashier’s check, which is considered as cash, constituted valid payment. The Villaruels’ refusal to accept was unjustified. The trial court correctly implemented the final judgment by accepting the payment and ordering the execution of the deed. The separate action for annulment filed by the Villaruels was a mere subterfuge to delay execution and could not prevail over the immutable final judgment. The trial court did not commit grave abuse of discretion in issuing its orders to enforce the settled rights of the parties under the final decision.