G.R. No. 139284; June 4, 2004
ASUNCION MACIAS, ET AL., petitioners, vs. MARIANO LIM, LEONORA MACIAS, THE BANK OF THE PHILIPPINE ISLANDS, and THE CENTRAL SAVINGS AND LOAN ASSOCIATION, respondents.

FACTS

The case involves Lot No. 1496, originally owned by Potenciana Unto. Upon her death, it passed to her heirs, leading to a complex series of sales and inheritances among the Mendez and Unto families. In 1968, Catalina Macias and other defendants executed an extrajudicial settlement, consolidating the property under their names, leading to the issuance of TCT No. 2833. They then mortgaged the property to respondent Central Savings & Loan Association (CSLA). Joaquin Unto and Victoriana Unto Vda. de Macias, claiming ownership of a 5/8 portion from prior unregistered sales, filed a complaint for reconveyance and cancellation of title (Civil Case No. 4823) against the Macias group and CSLA. The trial court dismissed the complaint in 1975, declaring the Macias defendants as the true owners and ordering the plaintiffs to vacate. This decision became final and executory.
Subsequently, due to a default on one mortgage, CSLA foreclosed on an undivided share of the lot. The property was eventually acquired by respondent Mariano Lim. Decades later, in 1997, the petitioners, who are successors-in-interest of the original plaintiffs, filed an “Urgent Omnibus Petition” with the trial court seeking to enforce the 1975 judgment, claiming it declared their ownership. The trial court and the Court of Appeals denied the petition.

ISSUE

Whether the petitioners are entitled to the enforcement of the 1975 decision in Civil Case No. 4823, which they claim declared their ownership over a portion of the subject property.

RULING

No. The Supreme Court affirmed the denial of the petition. The legal logic is clear: the 1975 judgment sought to be enforced was rendered against the petitioners’ predecessors, not in their favor. A careful reading of the 1975 decision shows it dismissed the complaint for reconveyance filed by Joaquin Unto and Victoriana Unto. It declared the Macias defendants as the true owners and ordered the plaintiffs to deliver possession and vacate the premises. Therefore, the judgment obligated the plaintiffs (petitioners’ predecessors) to surrender the property, not the defendants to reconvey it. The petitioners, as successors-in-interest, stepped into the shoes of the losing plaintiffs and cannot now seek to enforce a judgment that imposed obligations upon them, not rights for them. The action for enforcement presumes a favorable judgment for the moving party. Since the 1975 decision was adverse to their predecessors’ claim, the petitioners have no right to demand its execution. The proper remedy for a party aggrieved by a final judgment is not an action for its enforcement, but other potential avenues which were not availed of in a timely manner. The Court upheld the finality of the 1975 adjudication.