G.R. No. 255252, December 04, 2023
GOVERNOR GWENDOLYN GARCIA-CODILLA, PETITIONER, VS. HONGKONG AND SHANGHAI BANKING CORP., LTD., RESPONDENT.

FACTS

This case involves the execution of a final and executory judgment for a sum of money. Respondent HSBC extended a credit facility to petitioner Garcia, doing business as a sole proprietorship, to finance the purchase of a barge. Garcia defaulted on her obligations. HSBC filed a complaint, and after protracted litigation, the Supreme Court, in a Minute Resolution dated August 22, 2012 in G.R. No. 177734, rendered a final judgment ordering Garcia to pay HSBC specific amounts. This Resolution became final and executory on February 25, 2013. Consequently, the RTC issued a Writ of Execution. After attempts to collect proved unsuccessful, HSBC filed an Urgent Ex-Parte Motion for an Alias Writ of Execution. The RTC granted the motion and issued the Alias Writ.
Garcia filed an Urgent Motion to Quash the Alias Writ before the RTC, arguing it was issued in violation of due process because HSBC’s motion was not set for hearing. The RTC denied her motion, and the Court of Appeals affirmed the denial. Garcia then elevated the case to the Supreme Court via a Petition for Review on Certiorari, contending that the RTC committed grave abuse of discretion by issuing the Alias Writ without a hearing and that the CA erred in affirming the RTC’s orders which allegedly lacked factual and legal bases.

ISSUE

Whether the Court of Appeals erred in affirming the RTC Orders that denied Garcia’s motion to quash the alias writ of execution.

RULING

The Supreme Court denied the petition and affirmed the CA’s ruling. The Court held that the RTC did not commit grave abuse of discretion in issuing the Alias Writ of Execution without a hearing. The legal logic is anchored on the nature of execution proceedings for a final and executory judgment. A writ of execution is a ministerial duty of the court once a judgment becomes final. The issuance of an alias writ is a continuation of this ministerial process to enforce the judgment. A hearing is not a mandatory requirement for such an issuance, especially when the judgment debtor’s liability has been conclusively settled by the Supreme Court. Garcia’s due process rights were not violated because the full panoply of due process rights was already afforded to her during the entire adjudication of the main case, which culminated in a final Supreme Court decision.
Furthermore, the Court ruled that the constitutional requirement for decisions to state clearly and distinctly the facts and the law applies only to decisions or resolutions on the merits of a case. The assailed RTC Orders pertained to the execution of a final judgment and were thus interlocutory in nature. They did not need to comply with the detailed articulation requirement applicable to decisions on the merits. The duty of the trial court at the execution stage is to enforce the final judgment, not to re-litigate the settled obligations. Therefore, the CA correctly found no grave abuse of discretion in the RTC’s issuance of the Alias Writ to give effect to the Supreme Court’s final and executory Minute Resolution. The execution must proceed to satisfy the judgment debt.