G.R. No. 118339 March 19, 1998
AURORA B. CAMACHO, petitioner, vs. COURT OF APPEALS, LEONCIA DIZON, RICARDO VALERA, DELFIN MANLAPID, JACOBE QUINTOS and SPOUSES GASPAR and ELENA QUINTOS, respondents.

FACTS

Respondents instituted an action for specific performance against petitioner concerning portions of Lot No. 26108. The trial court ruled for respondents on December 20, 1974. The Court of Appeals affirmed the judgment on January 30, 1981, and the Supreme Court denied the petition for review on March 21, 1983, which became final and executory on May 23, 1983. A writ of execution was issued on August 26, 1983. Petitioner moved to defer execution on September 28, 1983, which the trial court denied on January 18, 1984. Petitioner filed various petitions challenging the execution, culminating in a Supreme Court resolution on February 26, 1986, denying her petition. A new writ was issued on September 26, 1986, but execution was hindered as petitioner allegedly failed to surrender her title copy, and it was discovered titles were transferred to her daughter in 1984. On April 14, 1987, respondents moved to compel surrender of titles. The trial court granted this against petitioner on August 11, 1987. Subsequent motions and incidents, including a change of counsel for respondents and vacancies in the trial court, remained unresolved. On June 15, 1992, respondents moved to implement the writ. Petitioner moved to dismiss on September 10, 1992, arguing the trial court lost jurisdiction as over five years had lapsed from finality. The trial court agreed and dismissed proceedings on November 19, 1992. The Court of Appeals reversed, finding the five-year period for execution by motion was suspended or interrupted by delays caused by petitioner’s actions and circumstances beyond respondents’ control, and remanded the case.

ISSUE

Whether a judgment may still be executed by mere motion after the lapse of five years from its finality.

RULING

Yes, under the specific circumstances of this case. The Supreme Court affirmed the Court of Appeals, denying petitioner’s appeal. The Court held that the five-year period under Section 6, Rule 39 of the Rules of Court for executing a judgment by motion was effectively interrupted or suspended. The delays were occasioned by petitioner’s own initiatives (her motion to defer execution and subsequent petitions, which consumed almost two and a half years) and for her advantage, as well as by circumstances beyond respondents’ control (such as unresolved motions and vacancies in the trial court). The Court invoked principles of equity and justice, noting respondents persistently pursued their rights and that literal adherence to technicality would result in absurdity and manifest injustice. The purpose of time limitations is to prevent obligors from sleeping on their rights, which respondents did not do.