G.R. No. 171469 ; August 11, 2008
V.C. PONCE COMPANY, INC., petitioner, vs. RODOLFO REYES, et al., respondents.

FACTS

The case originated from a 1963 complaint for annulment of sale filed by Eusebia de Leon against petitioner V.C. Ponce Company, Inc. over a parcel of land covered by TCT No. 97084, which petitioner had subdivided. Respondents, who had executed contracts to sell with petitioner for individual lots prior to the case, filed a complaint-in-intervention. In 1989, de Leon’s estate and petitioner entered into a compromise agreement, leading to the dismissal of the main case. Respondents, however, proceeded to trial on their intervention.
The Pasay City RTC ruled in favor of respondents in a 1989 decision, declaring their contracts to sell valid and ordering petitioner to deliver clean titles upon respondents’ full payment. This decision was affirmed by the Supreme Court in 1991. During execution, respondents consigned their payments as ordered, but petitioner refused to surrender its titles. Consequently, the RTC issued multiple orders and writs to enforce the judgment, eventually citing petitioner for contempt.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s order cancelling TCT No. 97084 and directing the issuance of individual titles to respondents.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The legal logic is anchored on the finality of the 1989 RTC decision, which had long become final and executory after the Supreme Court’s 1991 affirmation. A final judgment is immutable and unalterable. The duty of the court is to order its execution. Petitioner’s prolonged refusal to comply with the writs of execution justified the trial court’s use of its coercive powers.
The RTC’s order cancelling the mother title, TCT No. 97084, was a valid exercise of its authority under Section 10, Rule 39 of the Rules of Court. This rule allows the court, when a party disobeys an order to execute a conveyance, to divest title from the disobedient party and vest it in others, with the force of a legal conveyance. Furthermore, Section 107 of the Property Registration Decree authorizes the court to order the annulment of an owner’s duplicate certificate and issue a new one if the holder refuses to surrender it. The cancellation was not a substantive alteration of the final judgment but a necessary procedural mechanism to achieve its execution, as petitioner’s obstinacy made the direct delivery of deeds impossible. The court’s actions were a proper implementation of the final judgment, not a modification of it.