G.R. No. 168414 , August 31, 2006
BENEDICTO S. AZCUETA, Petitioner, vs. LA UNION TOBACCO REDRYING CORPORATION (LUTORCO), ET AL., Respondents.

FACTS

La Union Ventures, Inc. (LUVI) owned several parcels of land where the offices of respondent corporations and the residence of individual respondents were located. On April 25, 1997, respondents took physical possession of these properties. Consequently, petitioner Benedicto Azcueta, as LUVI’s corporate secretary, filed a forcible entry case (Civil Case No. 483) before the Municipal Trial Court (MTC) of Aringay. The MTC initially dismissed the case for lack of jurisdiction, deeming it an intra-corporate dispute, but the Court of Appeals reinstated it, a decision affirmed by the Supreme Court. The MTC then proceeded to trial and rendered a decision in favor of LUVI, ordering respondents to vacate and pay compensation.
During the execution stage, LUVI, under a new president, Julie Dyhengco, sent a letter to the MTC judge stating that LUVI’s possession was never disturbed and the issues had been settled internally, requesting the dismissal of the case. Based on this, the MTC issued an order lifting the writ of execution. Petitioner Azcueta, claiming to represent the legitimate board, challenged this order before the Regional Trial Court (RTC), which ruled in his favor. The Court of Appeals reversed the RTC, holding that the MTC’s order was interlocutory and not subject to certiorari, and that the letter from LUVI’s new president rendered the forcible entry judgment moot.

ISSUE

Whether the Court of Appeals erred in setting aside the RTC’s decision which affirmed the enforceability of the MTC’s final judgment in the forcible entry case.

RULING

Yes, the Court of Appeals erred. The Supreme Court reversed its decision and reinstated the RTC’s ruling. The legal logic is twofold. First, the MTC’s judgment in the forcible entry case had long become final and executory. A final judgment can only be altered or vacated through specific post-judgment remedies, not through a mere letter from a party. The letter from LUVI’s new president did not constitute a proper motion for reconsideration or a compromise agreement that could validly affect the final judgment. Second, the principle of immutability of final judgments applies. The MTC’s order lifting the writ of execution, based solely on an unverified letter, effectively amended the final judgment without legal basis, constituting grave abuse of discretion correctible by certiorari. The RTC, therefore, correctly annulled the MTC’s interlocutory orders. The subsequent internal corporate changes in LUVI’s management did not nullify the final judgment in a possessory action, which primarily concerns physical possession, not ownership or intra-corporate relations. Possession must be immediately restored to LUVI through its legitimate representative, the petitioner.