Maravilla v. Tupas
Heirs of Zosimo Q. Maravilla v. Privaldo Tupas, G.R. No. 192132, September 14, 2016
- Procedural (Remedial Law)
- Civil Law
- supervening event
- immutability of final judgments
- execution of judgment
- Boracay
- Regalian doctrine
- inalienable public land
- forest land
- void contract
- deed of sale
- Public Land Act
- quieting of title
- partition
I. Facts of the Case
The heirs of the late Zosimo Maravilla claimed 10,000 square meters of land in Diniwid, Balabag, Malay, Aklan (Boracay) under a 1975 Deed of Sale from the late Asiclo Tupas, whose heir, respondent Privaldo Tupas, remained in possession. After the Maravilla heirs won a final judgment in a partition case, they moved for execution. The Supreme Court then declared Boracay state-owned public land in the Boracay Decision, and the question became whether that ruling could stop execution of the final judgment.
February 8, 1975
The late Zosimo Maravilla claimed ownership of 10,000 square meters of land in Diniwid, Barangay Balabag, Malay, Aklan by virtue of a Deed of Sale purportedly executed by the late Asiclo S. Tupas. Respondent Privaldo Tupas and the other heirs of Asiclo maintained occupation and possession of portions of the property.
Maravilla filed a case for quieting of title with recovery of possession and damages before RTC Kalibo, Aklan, Branch 9 (Civil Case No. 4338). The RTC upheld the deed of sale only as to one-half (about 5,000 sq. m.) of the conjugal property, ordered the portions delineated, ordered defendants to refund P7,000, and ordered Maravilla to pay P10,000 attorney's fees and litigation expenses.
August 28, 1996
Maravilla appealed to the CA, questioning that he was awarded only one-half of the area sold. The CA set aside the RTC decision and declared Maravilla owner of a 10,000 sq. m. undivided share in the 36,382 sq. m. parcel. It directed partition (extrajudicial or judicial), ordered defendants to turn over the allocated portion, and dismissed Special Proceedings No. 39517.
October 21, 1999
Maravilla filed another case for partition and damages before RTC Kalibo, Branch 6.
March 31, 2003
The RTC ruled that the one-hectare portion in the Sketch Plan was Maravilla's rightful share. It ordered defendants to restore possession and to pay reasonable compensation of P5,000 monthly starting 1990 until possession is restored.
April 13, 2007
Respondent appealed to the CA, which dismissed the appeal on the ground of res judicata, finding identity of facts and evidence between the quieting of title case and the partition case. The RTC decision became final and executory on May 21, 2007.
October 8, 2008
In DENR v. Yap and Sacay v. DENR (the Boracay Decision), the Supreme Court declared Boracay as state-owned/public land, except for lands already covered by existing titles.
October 31, 2008
Maravilla filed a Motion for Execution of the March 31, 2003 RTC Decision.
February 2, 2009
The RTC granted the motion for execution. Respondent's motion for reconsideration was denied in an Order dated April 7, 2009.
November 11, 2009
Respondent filed a petition for certiorari with the CA, arguing that the Boracay Decision was a supervening event and that the deed of sale over unregistered land was void because Boracay is inalienable. The CA granted the petition and nullified the RTC Orders of February 2 and April 7, 2009. It reasoned that Asiclo could not sell what he did not own because the land was not alienable at the time of sale, and that execution would give Maravilla undue advantage. Reconsideration was denied on March 17, 2010.
May 25, 2010
The Maravilla heirs filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, seeking to reinstate the execution of the final RTC decision.
II. Issues
Whether or not the Court's decision in DENR v. Yap and Sacay v. DENR (the Boracay Decision) can be considered a supervening event.
Whether or not such a supervening event can prevent the execution of a judgment that has already attained finality.
Whether or not the 1975 Deed of Sale over the unregistered Boracay property is valid and can support petitioners' claim of ownership, given that the property was not alienable at the time of sale.
III. Ruling
Whether or not the Court's decision in DENR v. Yap and Sacay v. DENR (the Boracay Decision) can be considered a supervening event.
The Boracay Decision is a supervening event. It declared Boracay state-owned, which negated petitioners' claim of ownership over the property after the judgment became final.
How the Court reasoned
- A supervening event is a fact that arises after a judgment becomes final and changes the parties' situation so that executing the judgment would be unjust or inequitable.
- The Boracay Decision, promulgated on October 8, 2008, came after the RTC decision became final on May 21, 2007 and while the motion for execution was pending.
- That decision held that Boracay, unclassified and not covered by existing titles, remained public land under the Regalian Doctrine, which presumes lands of the public domain belong to the State.
- Private claimants needed to show that the land had been classified as alienable and disposable, but no such classification existed before Proclamation No. 1064 (2006), and the property is unregistered.
- Petitioners' claim rested on a sale of unregistered Boracay land, which that ruling undermined. This made the decision a new, material circumstance that arose after finality.
“With the above disquisitions, this Court's decision in _The Secretary of the Department of Environment and Natural Resources (DENR), et al. v. Yap, et al._ and _Sacay, et al. v. the Secretary of the DENR, et al._ is, therefore, considered as a supervening event that can stay the execution of a judgment that has already attained finality.”
Rule applied
Doctrine on supervening events as an exception to the immutability of final judgments; Regalian Doctrine; Commonwealth Act No. 141 (Public Land Act); Presidential Decree No. 705, Sec. 3(a).
Whether or not such a supervening event can prevent the execution of a judgment that has already attained finality.
A supervening event can stop execution of a final judgment. The Court of Appeals was correct to set aside the orders granting execution.
How the Court reasoned
- A final judgment is immutable, and the winning party is generally entitled to execution as a matter of right.
- One recognized exception is a supervening event, meaning facts arising after finality that make execution inequitable.
- Because the Boracay Decision negated the claim of ownership on which the judgment was founded, enforcing the judgment would give petitioners a property right they could not legitimately hold.
- The Court of Appeals therefore did not err in nullifying the RTC's orders of February 2 and April 7, 2009 granting execution, and in preventing undue advantage to petitioners.
“As such, the CA is then correct in ruling that with this Court's pronouncement that Boracay is state-owned, petitioners' claim of ownership over the subject property is negated, thus:”
Rule applied
Exception to the principle of immutability of final judgments and execution as a matter of right, for supervening events that make execution unjust or inequitable.
Whether or not the 1975 Deed of Sale over the unregistered Boracay property is valid and can support petitioners' claim of ownership, given that the property was not alienable at the time of sale.
The 1975 Deed of Sale is void because the land was forest land, not alienable, when it was sold. Thus it cannot support petitioners' claim of ownership.
How the Court reasoned
- Under Article 1347, only things within the commerce of man may be the object of a contract, and under Article 1409 contracts whose object is outside commerce are inexistent and void from the beginning (void ab initio).
- Public lands remain part of the public domain until the President classifies them as alienable and disposable, and forest land cannot be owned privately however long it has been occupied.
- At the time of the 1975 sale, the Boracay property had not been declared alienable and disposable, so Asiclo Tupas owned nothing that he could transfer.
- Since the sale was void from the start, it could produce no rights for Maravilla, and the Boracay Decision merely confirmed that no valid ownership existed.
- The Court therefore denied the petition and affirmed the Court of Appeals.
“The petition lacks merit.”
Rule applied
Articles 1347 and 1409 of the Civil Code (things outside the commerce of man cannot be the object of a contract, and such contracts are void ab initio); Regalian Doctrine; Sections 6 and 7, Commonwealth Act No. 141.
Doctrines
A final and executory judgment is immutable, and its execution is a matter of right, but a supervening event, a fact arising after finality that makes execution unjust or inequitable, may stay or prevent execution.
Under the Regalian Doctrine, all lands of the public domain belong to the State. Unclassified public land, including forest land, is inalienable until declared alienable and disposable, and the Boracay Decision declaring Boracay public land is a supervening event that can stay execution of a final judgment.
A contract whose object is outside the commerce of man, such as inalienable public land, is void ab initio under Articles 1347 and 1409 of the Civil Code and produces no rights.
Final Disposition
WHEREFORE, the petition is DENIED. Consequently, the Decision dated November 11, 2009 and the Resolution dated March 17, 2010 of the Court of Appeals are AFFIRMED.
Notes
The Court affirmed the CA decision despite the finality of the RTC judgment and the res judicata ruling in the earlier appeal.