G.R. No. L-27816 May 29, 1970
FEDERICO AGUILAR, petitioner, vs. HON. HONORATO B. MASAKAYAN, Judge, Court of First Instance of Rizal, 7th Judicial District, Branch V, Quezon City and RENE KNECHT, respondents.

FACTS

Petitioner Federico Aguilar obtained a final money judgment against private respondent Rene Knecht for P10,922.50, plus 12% interest, attorney’s fees, and costs. Upon execution, the sheriff levied on Knecht’s properties, including three polo horses. Knecht made a partial payment of P13,511.65, leaving an unpaid balance of P1,132.55, which primarily represented sheriff’s fees and expenses advanced by Aguilar. Knecht filed a motion to lift the attachment, questioning some of these expenses. At a hearing on April 15, 1967, Aguilar’s counsel, upon the court’s suggestion, conditionally agreed to accept a reduced sum of P500.00 in full settlement, provided Knecht accepted and paid it that same day. Knecht’s counsel rejected the offer. Two days later, on April 17, 1967, the respondent judge issued an order stating that Knecht’s counsel had manifested his client’s agreement to pay the P500.00, and it ordered the attachment lifted and the case terminated upon such payment. Aguilar moved to set aside this order, arguing his offer was conditional and had been withdrawn upon rejection, and that the court had no authority to reduce the final judgment debt. The court denied his motion, noting the P500.00 had been paid to the sheriff. Aguilar filed this certiorari petition to annul the court’s orders and enforce the full balance.

ISSUE

Whether the respondent court acted without or in excess of its jurisdiction or with grave abuse of discretion in issuing its orders of April 17, 1967 and May 10, 1967, which effectively reduced the amount due under a final and executory judgment based on a conditional compromise offer that had been rejected.

RULING

Yes. The Supreme Court granted the writ of certiorari, annulled the questioned orders, and directed the issuance of a writ of execution for the unpaid balance. The Court held that Aguilar’s offer to accept P500.00 was a conditional proposal that required Knecht’s acceptance and payment on April 15, 1967. Knecht’s rejection of the offer on that day entitled Aguilar to withdraw it. The respondent court’s subsequent order, based on Knecht’s belated change of mind, improperly imposed a withdrawn offer on Aguilar. Furthermore, the balance of P1,132.55 represented lawful sheriff’s fees and execution expenses, which are recoverable as costs by the prevailing party under established jurisprudence. Once a judgment becomes final and executory, the trial court’s jurisdiction is limited to its enforcement; it cannot alter or modify the judgment to avoid its full satisfaction. The respondent court therefore exceeded its authority.