G.R. No. 139370; July 4, 2002
RENE KNECHT and KNECHT, INC., petitioners, vs. UNITED CIGARETTE CORP., represented by ENCARNACION GONZALES WONG, and EDUARDO BOLIMA, Sheriff, Regional Trial Court, Branch 151, Pasig City, respondents.

FACTS

Rose Packing Company, Inc., through its President Rene Knecht, agreed to sell three parcels of land to United Cigarette Corporation (UCC) for ₱800,000. UCC paid earnest money. The agreement required UCC to assume Rose Packing’s ₱250,000 overdraft obligation with Philippine Commercial and Industrial Bank (PCIB). However, Rose Packing’s actual obligation exceeded this amount, and PCIB demanded additional collateral from UCC, which UCC did not provide. Rose Packing then offered the property to other buyers without returning UCC’s earnest money. Consequently, UCC filed a complaint for specific performance and damages.
The trial court ruled in favor of UCC, ordering Rose Packing and Knecht to convey the property under the original terms, deducting the earnest money and any obligation exceeding ₱250,000 from the purchase price. This decision was affirmed by the Court of Appeals and became final after the Supreme Court denied review. During execution, the trial court issued orders directing the sheriff to execute the deed of sale. Petitioners Knecht and Knecht, Inc. (the latter claiming to be the new owner) filed multiple motions and petitions to resist execution, arguing the judgment could no longer be enforced and that a new entity now owned the property.

ISSUE

Whether the trial court’s orders for the execution of the final and executory judgment in favor of UCC are valid, and whether petitioners can relitigate the issue of ownership.

RULING

The Supreme Court upheld the validity of the execution orders and denied the petition. The core legal principle is the immutability of final judgments. The decision in Civil Case No. 9165, which ordered the conveyance of the property to UCC, had long become final and executory. A final judgment can no longer be altered, amended, or modified, even for errors of law or fact. The petitioners’ protracted efforts to resist execution through various motions and petitions constituted improper collateral attacks on this immutable judgment.
The Court rejected the claim of Knecht, Inc. as a successor-in-interest. The final judgment had already decreed UCC as the rightful owner entitled to conveyance. Any subsequent transfer by Rose Packing to Knecht, Inc. was invalid as it involved property it no longer lawfully owned, having been divested of title by the court’s final order. The execution was the ministerial duty of the court to enforce this settled right. The doctrine of res judicata bars the re-litigation of the same issue of ownership already conclusively determined. The Court emphasized that endless litigation is detrimental to justice, and the case must conclusively end.