G.R. No. 124611; March 20, 2003
WENONAH L. MARQUEZ AZARCON, petitioner, vs. HOUSING AND LAND USE ARBITER CHARITO BUNAGAN, BOARD OF COMMISSIONERS (SPECIAL DIVISION), EQUITY HOMES, INC., SAGANA CONSTRUCTION AND DEVELOPMENT CORP. and J. M. BUILDERS, INC., respondents.

FACTS

Petitioner Wenonah Azarcon entered into a contract to sell a house and lot with respondents Sagana Construction and J.M. Builders. After her SSS loan application was disapproved, she offered to pay the balance in cash, but the vendors refused unless she paid interest. Azarcon filed a complaint with the HLURB. The Board of Commissioners’ final decision ordered Azarcon to pay the balance of the purchase price and required her to pay monthly rentals for her occupancy, which would form part of the purchase price. The decision became final.
Azarcon paid the full balance of the purchase price on July 22, 1993. However, the vendors refused to execute the deed of sale and deliver the title, insisting she still owed rentals. Both parties filed motions for execution. The Housing Arbiter granted the vendors’ motion, issuing a writ to compel Azarcon to pay the rentals, ruling her payment of the principal balance did not discharge all obligations. The Board and later the Court of Appeals upheld this execution.

ISSUE

Whether the Writ of Execution, which enforced the payment of rentals from Azarcon even after her full payment of the principal purchase price, was in accordance with the final HLURB decision.

RULING

No. The Supreme Court reversed the Court of Appeals and set aside the Writ of Execution. The legal logic centers on the proper interpretation of the final and executory HLURB decision. The Court examined the decision’s dispositive portion and its underlying rationale. The decision ordered Azarcon to pay rentals “reckoned from the time of her occupancy… until the amount set forth in the preceding order is fully paid,” with rentals forming part of the purchase price.
Critically, the Court found that the Board’s own discussion characterized the rental payment as an “interim scheme” or an “equitable payment for use of the premises” applicable only until a substitute method for paying the balance was settled. Since Azarcon fully paid the principal balance shortly after the decision’s finality, the interim purpose for the rental obligation ceased. To enforce further rental payments would alter the decision’s terms, effectively imposing an additional penalty not intended by the Board, which had earlier absolved Azarcon of fault for the payment delay. A writ of execution must conform strictly to the judgment it seeks to enforce and cannot modify or expand the judgment’s scope. The challenged writ varied the decision’s terms by enforcing a conditional obligation whose condition had been extinguished by full payment, constituting a grave abuse of discretion.