G.R. No. 208614 November 7, 2017
SIMEON TRINIDAD PIEDAD (deceased) survived and assumed by his heirs, namely: ELISEO PIEDAD (deceased)*, JOEL PIEDAD, PUBLIO PIEDAD, JR., GLORIA PIEDAD, LOT PIEDAD, ABEL PIEDAD, ALI PIEDAD, and LEE PIEDAD, Petitioners vs. CANDELARIA LINEHAN BOBILLES and MARIANO BOBILLES, Respondents

FACTS

Simeon Piedad successfully sued respondents Candelaria and Mariano Bobilles for the annulment of a forged deed of sale over a property. The trial court’s 1992 decision, affirmed by the Court of Appeals in 1998, declared the sale void and ordered respondents to vacate and pay damages. A writ of demolition was issued in 2001. However, respondents filed a separate petition for probate of Simeon’s will and obtained a temporary restraining order (TRO) against the sheriff implementing the demolition from another branch of the Regional Trial Court (RTC). The judges who issued the TRO and failed to resolve subsequent motions were later found administratively liable by the Supreme Court for gross ignorance of the law, as they improperly interfered with a co-equal court’s final judgment.
Over a decade after the finality of the judgment, petitioners filed a motion to resume the demolition. The RTC denied the motion, ruling that the judgment could no longer be enforced by mere motion as the five-year period for execution by motion had lapsed, and a separate action for revival of judgment was required. The Court of Appeals affirmed this denial. Petitioners elevated the case to the Supreme Court, arguing that the respondents’ own fraudulent and dilatory tactics caused the delay.

ISSUE

Whether the final and executory judgment in favor of petitioners can still be enforced by motion, despite the lapse of the five-year period for execution by motion, on grounds of equity.

RULING

Yes. The Supreme Court granted the petition and ordered the execution of the 1998 final judgment. The Court emphasized that while the general rule under Section 6, Rule 39 of the Rules of Court mandates that a judgment may be executed by motion only within five years from its finality, and thereafter by a separate action for revival, this rule is not absolute. Equity tempers the rigor of the law and may justify an exception where a strict application would result in manifest injustice.
The legal logic is clear: the extraordinary delay in execution was directly and solely attributable to the respondents’ bad faith. They employed fraudulent schemes, including filing a baseless probate case and obtaining an unlawful injunction from a co-equal court, which the Supreme Court itself condemned in an administrative case. To require petitioners to file a separate revival action after being obstructed for years by the respondents’ own malicious maneuvers would be to reward deceit and cause grave injustice. Equity demands that respondents cannot benefit from the delay they intentionally created. Therefore, the judgment remains enforceable by motion to prevent a travesty of justice.