G.R. No. 186192 ; August 25, 2010
THE HEIRS OF MATEO PIDACAN AND ROMANA BIGO, NAMELY: PACITA PIDACAN VDA. DE ZUBIRI AND ADELA PIDACAN VDA. DE ROBLES, Petitioners, vs. AIR TRANSPORTATION OFFICE, represented by its Acting Director BIENVENIDO MANGA, Respondent.

FACTS

Petitioners are the heirs of spouses who owned a parcel of land in San Jose, Occidental Mindoro. In 1948, respondent Air Transportation Office (ATO) appropriated a portion of this property for use as an airport, constructing facilities and expanding the runway without payment. After protracted litigation, the Supreme Court, in a 2007 Decision, affirmed the expropriation of the land and ordered ATO to pay just compensation of ₱65,668,185.43 with 6% interest from February 1, 2001. This Decision became final and executory.
Petitioners subsequently filed a Motion for Execution in the Regional Trial Court (RTC) to enforce the judgment. The ATO opposed, arguing that satisfaction of the money judgment must follow the procedure under Commonwealth Act No. 327 and P.D. No. 1445, requiring claimants to file their monetary claims with the Commission on Audit (COA). The RTC denied the Motion for Execution, citing these laws and Administrative Circular No. 10-2000, which urges caution in issuing writs of execution against government agencies. The RTC directed petitioners to pursue their claim with the COA instead.

ISSUE

Whether the final and executory judgment of the Supreme Court ordering ATO to pay just compensation can be enforced via a writ of execution from the RTC, or whether petitioners must first file a claim with the Commission on Audit.

RULING

The Supreme Court granted the petition and ordered the RTC to issue the writ of execution. The legal logic is clear: a final and executory judgment must be executed as a matter of right. The doctrine of finality of judgments is immutable; the losing party has no right to demand further proceedings. The RTC erred in relying on COA audit rules to deny execution. While Commonwealth Act No. 327 and P.D. No. 1445 prescribe the general procedure for settling money claims against the government, this procedural requirement is not applicable when the government agency’s liability has already been adjudicated with finality by a competent court.
The Court distinguished between an unliquidated claim, which must first be filed with the COA, and a final judgment, which is a liquidated claim enforceable by execution. The 2007 Supreme Court Decision transformed petitioners’ claim into a definite amount owed by the government. To require a second filing with the COA would be redundant, unjust, and would violate the rule on finality of judgments. It would also constitute an unconstitutional impairment of the judiciary’s authority. Administrative Circular No. 10-2000, which advises caution, cannot override a final judgment from the Supreme Court. The ATO, having actively litigated the case to its conclusion, is legally and morally obligated to comply with the final decree. The duty now shifts to the ATO to initiate the requisite budgetary processes to satisfy the judgment.