GR 134462; (October, 2004) (Digest)
G.R. No. 134462; October 18, 2004
MAYON ESTATE CORPORATION, petitioner, vs. MARIETTA ALTURA, et al., respondents.
FACTS
Petitioner Mayon Estate Corporation, along with co-owners, filed a forcible entry case (Civil Case No. 890) in 1976 against certain individuals and associations. The Municipal Trial Court (MTC) ruled in favor of the petitioner on June 26, 1979, ordering the defendants to vacate. A writ of execution was issued on April 26, 1980, but implementation failed. In 1985, the MTC granted a motion for a writ of demolition. Respondents then filed a Petition for Prohibition (Civil Case No. 739-A) before the Regional Trial Court (RTC) to enjoin the demolition, arguing the MTC’s 1985 order was issued beyond the five-year period for execution by motion. The petitioner was declared in default in that case.
The RTC decided in favor of the respondents in 1986, issuing a writ of prohibition against enforcing the MTC decision. This RTC decision became final and executory in 1987. Despite this, the MTC, upon the petitioner’s motions, subsequently issued second, third, and fourth alias writs of demolition between 1988 and 1995, leading to partial demolitions. In 1995, the respondents themselves moved to lift the 1986 writ of prohibition to allow full execution. The RTC granted this motion. The Court of Appeals later reversed this 1995 RTC order, reinstating the writ of prohibition.
ISSUE
Whether the Court of Appeals erred in reversing the RTC’s 1995 order which lifted the final and executory writ of prohibition, thereby barring further execution of the 1979 MTC judgment.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle is the immutability of final judgments. The RTC’s 1986 decision in Civil Case No. 739-A, which prohibited the enforcement of the MTC’s 1979 decision, became final and executory in 1987. A final judgment can no longer be altered, amended, or modified, even if the modification is correct. The RTC, in its 1995 order, effectively modified its own final judgment by lifting the prohibition, which is a substantive alteration not permitted. The petitioner’s recourse, after the prohibition became final, was not to seek further alias writs from the MTC but to file an independent action to revive the 1979 MTC judgment under Section 6, Rule 39 of the Rules of Court, as the five-year period for execution by motion had lapsed. The petitioner’s negligence in allowing the RTC prohibition case to proceed to a final default judgment against it precludes it from assailing that judgment’s validity. The writ of prohibition, having attained finality, stands as a permanent bar to the execution of the 1979 decision by mere motion or alias writs from the MTC.