G.R. No. 146754 ; March 21, 2012
SPOUSES JESSE CACHOPERO and BEMA CACHOPERO, Petitioners, vs. RACHEL CELESTIAL, Respondent.

FACTS

Respondent Rachel Celestial filed an ejectment case against her brother, petitioner Jesse Cachopero, and his spouse, before the Municipal Trial Court (MTC) of Midsayap. Celestial alleged the spouses were living in her old house on her lot out of tolerance and refused to vacate when she decided to demolish it. The parties entered into a Compromise Agreement, approved by the MTC in a judgment dated August 10, 1989. The agreement stipulated that the spouses would vacate and transfer the old house to the back of Celestial’s lot within eight months, with Celestial shouldering specified expenses and providing an exit alley.
The Deputy Sheriff subsequently filed a return stating the defendants were “out of the real estate property of the plaintiff” and the boundary was distinct. Celestial, however, moved for an alias writ of execution, contending a portion of the house extending beyond her lot onto an adjoining parcel of land (the subject land, a dried-up creek bed) was not demolished. The MTC denied her motion, ruling its jurisdiction was limited to Celestial’s lot as described in the ejectment complaint. Celestial then filed a petition for mandamus with the Regional Trial Court (RTC), which was granted, ordering the MTC to issue an alias writ to enforce the compromise agreement fully. The Court of Appeals affirmed the RTC.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s order for the issuance of an alias writ of execution to enforce the compromise agreement, specifically regarding the demolition of the portion of the house standing outside Celestial’s lot.

RULING

The Supreme Court denied the petition and affirmed the appellate court. The compromise agreement, having been judicially approved, had the force of res judicata and was immediately executory. The agreement’s clear and unambiguous terms obligated the spouses Cachopero to “vacate the premises in question and transfer the old house.” The “premises in question” referred to the entire old house, a significant part of which encroached on the adjacent subject land. The agreement’s objective was the complete removal and relocation of the entire structure, not merely vacating Celestial’s lot. The Sheriff’s return was incorrect and incomplete, as it focused only on the lot boundaries while failing to execute the core obligation to transfer the house.
The Court rejected the petitioners’ argument that a supervening event—their claim of ownership over the subject land—justified staying execution. For a supervening event to halt execution, it must create a substantial change in the parties’ rights occurring after the judgment, rendering execution unjust or inequitable. The petitioners’ claim of ownership, even if pursued in a separate action, did not constitute such an event as it pertained to a right allegedly existing prior to the judgment. The compromise agreement settled the ejectment case conclusively, and the obligation to transfer the house remained enforceable. Thus, the alias writ was properly issued to execute the judgment according to its precise terms.