G.R. No. 143510 November 23, 2005
Roman Catholic Archbishop of Caceres, Petitioner, vs. Heirs of Manuel Abella, represented by MERCEDES N. ABELLA, Respondents.

FACTS

The dispute involves a one-hectare parcel of land in Naga City. The Heirs of Manuel Abella filed a forcible entry case against the Roman Catholic Archbishop of Caceres, who claimed the land was donated to him in 1981 in exchange for monthly masses. The Municipal Trial Court (MTC) dismissed the complaint, upholding the Archbishop’s possession based on an alleged onerous donation. This decision was affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA), becoming final and executory.
While the forcible entry appeal was pending, the heirs filed a separate action for quieting of title over the same property. The RTC, in this second case, declared the heirs as the rightful owners, finding no valid donation for the one-hectare lot. This decision was likewise affirmed by the CA and the Supreme Court, becoming final and executory after the judgment in the forcible entry case. When the Archbishop moved to execute the final judgment in the forcible entry case, the MTC denied the motion.

ISSUE

Whether the final and executory judgment in the forcible entry case, awarding possession to the Archbishop, can still be executed after a subsequent final judgment in the quieting of title case has declared the heirs as the true owners of the property.

RULING

The Supreme Court denied the petition and affirmed the denial of execution. The Court ruled that while the judgment in the forcible entry case had become final, its execution was correctly barred by a supervening event. The supervening event was the final and executory decision in the quieting of title case, which conclusively resolved the issue of ownership in favor of the heirs.
The legal logic is grounded in the principle of immutability of final judgments, which admits exceptions, one of which is the occurrence of supervening events. A supervening event is a fact or new circumstance that transpires after a judgment has attained finality. Here, the final judgment in the quieting of title case, declaring the heirs as owners, constituted such a supervening event to the earlier final judgment in the forcible entry case. Since ownership includes the right to possess, to allow execution of the forcible entry judgment would unjustly enforce possession in favor of a party who has been conclusively adjudged not to be the owner. The right to execute a final judgment, while generally ministerial, must yield to equitable grounds when its enforcement would lead to an unjust and contradictory result, as it would violate the settled right of ownership established in the later final judgment.