GR L 3777; (October, 1951) (2) (Digest)
G.R. No. L-3777 and L-3778; October 31, 1951
VALENTINA ZAMORA and BONIFACIO DIONES, plaintiffs-appellees, vs. TOMAS MEDRAN ET AL., defendants-appellants. (G.R. No. L-3777)
TOMAS MEDRAN, plaintiff-appellant, vs. BONIFACIO DIONES, defendant-appellant. (G.R. No. L-3778)
FACTS
In November 1945, the Court of First Instance of Mindoro rendered a consolidated judgment declaring Tomas Medran the owner of a 2.5-hectare land and ordering Bonifacio Diones to vacate the land, return it to Medran, and pay Medran P1,000 as damages and the costs of the two cases. The judgment could not be enforced until December 1949 due to dilatory steps by Diones. Upon Medran’s petition, the clerk of court issued an order of execution that included the P1,000 damages, P89.25 costs, and interest at six percent from May 17, 1941. Diones objected to the payment of interest, depositing only P1,089.52 with the clerk of court and arguing that the judgment did not include interest. The Court of First Instance upheld Diones’s objection. Tomas Medran appealed.
ISSUE
Whether the writ of execution can validly include the payment of interest on the monetary award when the dispositive part of the final and executory judgment did not provide for such interest.
RULING
The Supreme Court affirmed the order of the Court of First Instance, ruling that the writ of execution cannot include interest because the judgment under execution failed to provide for it. The Court held that there is no statute directing that legal interest shall necessarily be collected in the execution of judgments for money. The writ of execution must conform strictly to the dispositive part of the judgment, which furnishes the guidance for enforcement. The dispositive part of the 1945 judgment ordered the payment of a specific sum as damages and costs but was silent on interest. The Court distinguished the cases cited by appellant Medran and found Rule 53, Section 6 of the Rules of Court (regarding interest on judgments of the Court of Appeals) inapplicable, as it is a principle of adjudication for appellate courts and not a self-executing regulation for all judgments. The Court also interpreted Rule 39, Section 8 as merely outlining the procedure for the sheriff to satisfy a judgment “with interest—if any has been ordered,” and not as a directive for the collection of interest on all judgments. Costs were awarded against appellant Medran.