G.R. No. 186322 ; July 8, 2015
ENRICO S. EULOGIO and NATIVIDAD V. EULOGIO, Petitioners, vs. PATERNO C. BELL, SR., ROGELIA CALINGASAN-BELL, PATERNO WILLIAM BELL, JR., FLORENCE FELICIA VICTORIA BELL, PATERNO FERDINAND BELL III, and PATERNO BENERAÑO BELL IV, Respondents.

FACTS

Respondents, the Bell siblings and their parents (Spouses Bell), filed a complaint against petitioners, the Eulogios, for annulment of documents, reconveyance, quieting of title, and damages (Civil Case No. 4581). The RTC declared the deed of sale over the residential house and lot as an equitable mortgage, null and void for lack of written consent from the beneficiaries (the Bell siblings) as required by the Family Code. The property was declared the family home of the respondents. However, the RTC also declared Spouses Bell liable to the Eulogios for ₱1,000,000 plus 12% interest per annum, as the transaction was deemed an unsecured loan. This decision was affirmed by the CA and became final. Upon execution, the RTC initially levied the property but later lifted the writ, recognizing it as a family home. The Eulogios moved for reconsideration, arguing that under Article 160 of the Family Code, the property’s value (allegedly exceeding ₱300,000 based on its sale price and commercial location) made it subject to execution. The RTC ordered a hearing to determine the property’s present market value. Respondents opposed, arguing res judicata and forum-shopping. The RTC proceeded, eventually ordering execution. Respondents filed a Petition for Certiorari with the CA, which enjoined the execution sale. The CA granted the petition, ruling that the basis for valuation under Article 160 is the actual value at the time of the family home’s constitution, not its present market value, and that the RTC committed grave abuse of discretion.

ISSUE

1. Whether petitioners are guilty of forum-shopping.
2. Whether a hearing to determine the value of respondents’ family home for purposes of execution under Article 160 of the Family Code is barred under the principle of res judicata.
3. Whether respondents’ family home may be sold on execution under Article 160 of the Family Code.

RULING

1. No, petitioners are not guilty of forum-shopping. Forum shopping involves filing multiple suits on the same cause of action to obtain a favorable judgment. The execution proceedings and the instant petition are a continuation of the main case (Civil Case No. 4581), not a separate action. Seeking reversal of an adverse order via certiorari is a sanctioned remedy and does not constitute forum shopping.
2. Yes, re-litigating the issue of the family home’s value is barred by res judicata (conclusiveness of judgment). The final decision in Civil Case No. 4581 declared the property a family home. The issue of its value for exemption purposes is deemed included in that declaration. Allowing a post-judgment valuation hearing would effectively re-open and contradict the final judgment that established the property’s status as a family home, which is prohibited.
3. No, respondents’ family home may not be sold on execution under Article 160 of the Family Code based on its present market value. Article 160 exempts the family home from execution “to the extent of the value allowed by law.” The Court ruled that the basis for this valuation is the actual value of the property at the time of its constitution as a family home, not its current or market value at the time of execution. The exemption is determined based on the value when the family home was established. Therefore, the RTC’s order for a hearing to determine the present market value was contrary to law.