G.R. No. 178591 ; July 26, 2010
SM SYSTEMS CORPORATION (formerly Springsun Management Systems Corporation), Petitioner, vs. OSCAR CAMERINO, EFREN CAMERINO, CORNELIO MANTILE, DOMINGO ENRIQUEZ, and HEIRS OF NOLASCO DEL ROSARIO, Respondents.

FACTS

Respondents were agricultural tenants on land owned by Victoria Homes, Inc. Victoria Homes sold the land to petitioner’s predecessor without notifying the tenants. The petitioner later mortgaged the property, which was foreclosed and subsequently redeemed. Respondents filed an action for legal redemption before the Regional Trial Court (RTC), which was decided in their favor. This decision was affirmed with finality by the Supreme Court in a prior case ( G.R. No. 161029 ). During execution, respondents deposited the redemption price with the RTC after petitioner refused to accept it. The RTC then cancelled petitioner’s titles and issued new ones in respondents’ names.
While execution was pending, petitioner entered into a Kasunduan (agreement) with four of the five respondents, wherein these respondents agreed to receive a compromise sum from petitioner. Petitioner then filed a Motion to Hold Execution in Abeyance based on this supervening event. The RTC denied the motion and disapproved the Kasunduan. The Court of Appeals affirmed this denial. Petitioner elevated the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s denial of the Motion to Hold Execution in Abeyance and its disapproval of the compromise Kasunduan.

RULING

The Supreme Court denied the petition and affirmed the assailed resolutions. The legal logic is anchored on the doctrine of finality of judgment and the nature of a supervening event. A judgment that has become final and executory is immutable and unalterable. The only recognized exceptions to its execution are a subsequent change in the law or supervening events which render its execution unjust and impossible.
The Court ruled that the Kasunduan did not constitute a valid supervening event that could stay execution. The compromise agreement was entered into by only four of the five prevailing parties/respondents. Oscar Camerino, a co-tenant with an indivisible interest in the redeemed property, did not sign it. His rights could not be prejudiced by an agreement to which he was not a party. Furthermore, the Kasunduan was executed pendente lite—after the final judgment but during the execution stage—and sought to vary the terms of a final and executory judgment. Allowing such a partial compromise would violate the immutability of the final judgment and undermine the judicial process. The RTC correctly disapproved the agreement and proceeded with the execution of the long-final decision.