G.R. No. 164914. October 5, 2005.
NATALIA REALTY, INC., Petitioner, vs. HON. MAURICIO M. RIVERA, Presiding Judge, Br. 73, Regional Trial Court, Antipolo City, BRANCH CLERK OF COURT GLORIA M. DE GUZMAN, DEPUTY SHERIFF ROLANDO P. PALMARES, ANTONIO MARTINEZ, FELIPE PADUA, MARIO PERFECTO and HERMITO SALUDEGA, Respondents.

FACTS

Petitioner Natalia Realty, Inc. filed an action for recovery of possession of land against private respondents in 1984. The trial court dismissed the case for failure to prosecute on August 26, 1991. This order became final as petitioner failed to appeal. Subsequently, the trial court granted private respondents’ motion and ordered petitioner to restore possession to them on April 20, 1992. Petitioner’s attempts to set aside these orders were denied, with the trial court and later the Court of Appeals emphasizing the finality of the dismissal order.
Private respondents moved for execution in 1995. The Court of Appeals, in a resolution, clarified which orders were final and executory, directing their execution. However, a subsequent RTC judge granted petitioner’s motion for reconsideration, citing a supervening event from another Supreme Court case. The Court of Appeals then reiterated its directive for execution and required the RTC judge to explain for potentially disobeying its lawful orders.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in reiterating its resolution directing the execution of final and executory orders and in requiring the RTC judge to comment for contempt.

RULING

The Supreme Court dismissed the petition and affirmed the actions of the Court of Appeals. The legal logic is anchored on the doctrine of finality of judgment. The trial court’s order of dismissal dated August 26, 1991, having been issued for failure to prosecute, constituted an adjudication on the merits under the Rules of Court. Since petitioner did not file a motion for reconsideration or an appeal within the reglementary period, that order became final and executory. Consequently, the trial court lost jurisdiction to amend or revoke it; its only remaining function was to order its execution. The subsequent order to restore possession was a logical consequence of this final dismissal.
The Supreme Court found no supervening event that warranted reopening the case. The cited ruling in another matter was irrelevant to the execution of the already final judgment in this specific case. The Court of Appeals acted correctly in reiterating its directive for execution to uphold the immutability of final judgments. Its action to require the RTC judge to comment was a proper exercise of its supervisory authority to ensure compliance with its lawful directives and to prevent undue delay. The Supreme Court condemned petitioner’s dilatory tactics, which had mocked the justice system for over two decades, and imposed costs against petitioner.