G.R. No. L-71033 and G.R. No. L-76330, July 29, 1988
The Heirs of Remigio Tan, namely Rosita Tan, Eduardo Tan, Eusebio Tan, Remigio Tan, Jr., Eufrosina Tan, and Virgilio Tan, petitioners, vs. The Honorable Intermediate Appellate Court, Florencia V. Tankeh, Ruperto Tankeh, Brigida T. Guingona, Aida T. Concepcion, Alejandro V. Tankeh and Ligaya Lualhati, in her behalf and in behalf of her minor children, Maria Nieves, Clemente Jr., Joseph and John Tankeh and Catherine L. Tankeh, respondents.

FACTS

This case involves the execution of a final judgment concerning the estate of the late spouses Don Eusebio Valdez Tankeh and Doña Hilaria Isabelo. Following the death of Doña Hilaria, a dispute arose among their children over certain properties, including the Folgueras, Rosario, and Carriedo properties. The plaintiffs, initially including Remigio Tan, sought recovery of shares allegedly illegally transferred. Upon Remigio’s death, his heirs were substituted. After a lengthy trial, the Court of First Instance dismissed the complaint and granted the defendants’ counterclaim, ordering the reconveyance of one-seventh shares in the disputed properties to each sibling of Remigio, and the payment of income shares and attorney’s fees. This decision was affirmed with modifications by the Intermediate Appellate Court and became final after the Supreme Court denied a petition for review.
During execution proceedings, the petitioners (heirs of Remigio) challenged the trial court’s order, arguing their liability should be limited to the value of the inheritance they received from Remigio. Separately, Eusebio V. Tan filed a petition in intervention, claiming deprivation of property without due process. These challenges led to the consolidated petitions before the Supreme Court, questioning the execution of the long-final judgment.

ISSUE

Whether the final and executory judgment can be modified during execution to limit the petitioners’ liability to the value of the inheritance they received from the decedent, Remigio Tan.

RULING

The Supreme Court denied the petitions and dismissed the intervention, upholding the execution of the final judgment. The Court emphasized the immutability of final judgments. The legal logic is anchored on the doctrine of finality of judgment, a cornerstone of judicial stability. Once a judgment becomes final and executory, it ceases to be subject to alteration by any court, except for the correction of clerical errors. The petitioners had ample opportunity during the original litigation and appeals to raise the issue of limiting their liability to the value of their inheritance. Their failure to do so at the appropriate procedural stages precludes them from raising it collaterally during execution. The Court clarified this is not a mere “procedural technicality” but a fundamental principle ensuring an end to litigation. The claim of deprivation of due process was rejected, as due process was satisfied through the prior full opportunity to be heard. The judgment sought to be executed was not void for lack of jurisdiction; it was a valid adjudication on the merits. Therefore, the trial court’s duty was purely ministerial—to execute the judgment as written. Allowing modification at this stage would undermine the very purpose of the judiciary to settle disputes with finality.