G.R. No. L-53620 January 31, 1985
PEDRO LONZAME, petitioner, vs. HON. AUGUSTO M. AMORES, Judge of the Court of First Instance of Manila, Branch XXIV, MELANIO FLORES and SEGUNDA MANUEL, respondents.

FACTS

Eufemia Blones owned Lot No. 19. In 1969, she sold a portion, Lot 19-A, to spouses Melanio Flores and Segunda Manuel under an unregistered “Kasunduan ng Pagbibilihan.” The Floreses made payments and took possession. In 1970, Blones mortgaged the entire Lot No. 19 to the Trinidad spouses to secure a loan. The mortgage was registered. The Floreses later sued Blones and the mortgagees. The court ordered Blones to accept the Floreses’ final payment and to register Lot 19-A in their names, subject to the mortgage. It also ordered Blones to pay the Trinidads; upon her default, the mortgage was foreclosed.
At the foreclosure auction, the entire Lot No. 19 (including 19-A) was sold, as it still had a single title. Petitioner Pedro Lonzame was the highest bidder. On auction day, Lonzame executed an “Option to Buy” in favor of the Floreses, giving them 15 days from court confirmation of the sale to buy Lot 19-A for P8,000. The sale was confirmed, and a sheriff’s deed issued. The Floreses later tendered P8,000, but Lonzame refused, arguing the option period had lapsed. The respondent judge, in the original case between the Floreses and Blones, issued orders compelling Lonzame to accept the tender.

ISSUE

Whether the respondent court acted with grave abuse of discretion in issuing orders compelling petitioner Lonzame to accept the tender of payment based on the “Option to Buy.”

RULING

Yes. The Supreme Court annulled the respondent court’s orders. The legal logic is twofold. First, the court’s decision in the original case between the Floreses and Blones had long become final and executory. That decision did not mention or incorporate the subsequent “Option to Buy” executed between Lonzame and the Floreses. A final judgment can no longer be amended or substantively modified by the court, except for clerical errors. The orders compelling Lonzame to accept payment effectively modified the final decision by enforcing a new, separate agreement, which exceeded the court’s jurisdiction.
Second, Lonzame was not a party to the original suit between the Floreses and Blones. He acquired the property at a public auction as a third-party purchaser. The unregistered “Kasunduan” between Blones and the Floreses did not bind Lonzame, as it was not annotated on the title. He could not be considered a successor-in-interest to Blones bound by that contract. His obligation, if any, arose solely from the separate “Option to Buy.” Any dispute regarding its terms, including the validity of the tender and the computation of the period, should be litigated in a separate action, not enforced through orders in a case already concluded. The respondent court therefore committed grave abuse of discretion.