G.R. No. L-26112. October 4, 1971.
REPUBLIC OF THE PHILIPPINES, ET AL., petitioners, vs. HON. JAIME DE LOS ANGELES, ET AL., respondents.

FACTS

This case originated from a final and executory judgment in G.R. No. L-20950 (May 31, 1965), where the Supreme Court affirmed a lower court decision ordering the reversion to the public domain of certain lands within Hacienda Calatagan that were found to be part of the foreshore or territorial sea. The titles covering these lands, originally held by respondents Ayala y Cia. and/or Alfonso Zobel and later purchased by the Dizons, were declared null and void. In the execution of that judgment, the petitioners sought a writ to recover the lands. The respondent judge, however, refused to issue the writ against respondents Ayala and Zobel, interpreting the L-20950 decision as having absolved them from liability because the Dizons, as purchasers, were found to be in good faith. The petitioners then filed the instant special civil action for mandamus to compel the issuance of the writ.

ISSUE

The core issue is whether the respondent judge committed a grave abuse of discretion in refusing to execute the final judgment in L-20950 against the original titling holders, Ayala y Cia. and Alfonso Zobel, based on his interpretation of that decision.

RULING

The Supreme Court, in a majority resolution, dismissed the petition for mandamus. The Court upheld the respondent judge’s interpretation and refusal to execute the judgment against Ayala and Zobel. The legal logic rests on the principle of the indefeasibility of a Torrens title and the correlative concept of a purchaser in good faith. The Court in L-20950, while annulling the titles for covering inalienable public land, explicitly found no showing that the Dizon spouses were not purchasers in good faith. By legal implication, if the subsequent purchasers (Dizons) are deemed in good faith, then the vendors (Ayala and Zobel) who relied on the same state-issued Torrens certificates must also be considered in good faith at the time of the sale. The Court reasoned that the shield of good faith provided by the Torrens system to the Dizons must equally protect their predecessors-in-interest. Consequently, the judgment in L-20950, which ordered reversion, was properly enforceable only against the Dizons as the registered owners and possessors in good faith, not against the respondents who had already parted with ownership. The Court emphasized that the lower court’s duty in execution is ministerial only to the extent of the judgment’s definitive terms, and the respondent judge correctly interpreted its scope.