GR 26117; (July, 1980) (Digest)
G.R. No. L-26117 July 17, 1980
J. ANTONIO ARANETA, petitioner, vs. ANTONIO M. PEREZ and the HONORABLE EMIGDIO V. NIETES, Judge of the Court of First Instance of Manila, respondents.
FACTS
The case originated from a promissory note executed by respondent Antonio M. Perez in favor of petitioner J. Antonio Araneta for P3,700.00. Upon Perez’s failure to pay, Araneta filed a collection suit. The Municipal Court rendered judgment on the pleadings in favor of Araneta, which was affirmed with modification by the Court of First Instance and later by the Supreme Court, making the judgment final and executory. Araneta subsequently moved for a writ of execution.
The trial court initially granted the motion for execution. However, Perez later informed the court that, as the judicial guardian of his daughter (the beneficiary of a trust administered by Araneta as trustee), he had been authorized by the guardianship court to assign P3,700.00 from the trust estate to Araneta. Perez also deposited P1,472.38 with the Clerk of Court, claiming it represented the remaining balance of his obligation. Based on these developments, the trial court reconsidered and set aside its earlier order granting execution.
ISSUE
Whether the trial court committed a grave abuse of discretion in denying the motion for execution of a final and executory judgment.
RULING
The Supreme Court ruled that the trial court did not commit grave abuse of discretion. While a final judgment is generally entitled to execution as a matter of right, the trial court’s duty is to ensure the execution conforms to law and justice based on prevailing facts. The court found that the issuance of a conventional writ of execution had become a superfluity.
The legal logic is that execution is meant to satisfy a judgment obligation. The incontrovertible facts showed that satisfaction was already possible through two specific means without a writ: first, by Araneta crediting to himself the P3,700.00 check corresponding to the guardianship court’s order of assignment from the trust estate; and second, by withdrawing the cash deposit made by Perez with the Clerk of Court for the claimed balance. The trial court’s order directing these actions instead of issuing a writ was a proper exercise of discretion to avoid an unnecessary and circuitous process. It effectively adapted the enforcement mechanism to the supervening events that offered a direct path to fulfillment of the judgment. The petition for certiorari and mandamus was therefore denied.