G.R. No. 112140 ; June 23, 2005
JESUS D. MORALES and CAROLINA NUQUI, petitioners, vs. COURT OF APPEALS, ISAAC OLIVA, MILAGROS OLIVA-OBUYES, ANTONIA OLIVA-OLEO, DANILO OLIVA and ROBERTO OLIVA, respondents.

FACTS

Spouses Isaac Oliva and Encarnacion dela Cruz owned a parcel of land in Bulacan. After Encarnacion’s death, their son Florentino borrowed the title, purportedly for a loan collateral, but failed to return it. The respondents (Isaac and his other children) later discovered that an Extrajudicial Settlement with Sale, allegedly bearing their forged signatures, had been registered, conveying the property to petitioners Jesus Morales and Carolina Nuqui. The respondents filed an action for nullification of the deed, reconveyance, and damages. The parties entered into a Stipulation of Facts agreeing that the case would be resolved based on an NBI examination of the signatures. The NBI report concluded the signatures were genuine. The trial court, based on the stipulation, rendered a Resolution declaring the petitioners as lawful owners and ordering the respondents to vacate, but deferred ruling on damages. The respondents filed a notice of appeal, but the trial court refused to give it due course, stating the judgment was not yet final as damages were still pending.

ISSUE

Whether the trial court’s Resolution dated 29 December 1983, which adjudicated ownership based on the Stipulation of Facts but deferred the award of damages, was a final and appealable judgment.

RULING

Yes, the Resolution was a final and appealable judgment. The Supreme Court held that a judgment that definitively settles the proprietary rights of the parties, leaving only the ministerial execution of a monetary claim for damages, is final for purposes of appeal. The core issue of ownership was conclusively determined by the trial court’s Resolution based on the parties’ binding stipulation. The deferred assessment of damages was merely a collateral consequence or a incidental matter that did not affect the finality of the adjudication on the principal relief. The Court emphasized that procedural rules should be liberally construed to secure a just, speedy, and inexpensive disposition of cases. To require the parties to await a separate ruling on damages before appealing the central issue of ownership would elevate technicality over substance and cause undue delay. Consequently, the respondents’ notice of appeal was timely filed, and the Court of Appeals erred in dismissing their appeal on the ground of prematurity. The case was remanded to the Court of Appeals for proper adjudication on the merits.