**Facts:**
1. **Initiation of Proceedings:** Ceferino S. Cabreza Jr. (respondent) filed a petition for the declaration of nullity of his marriage to Amparo Robles Cabreza (petitioner) at the Regional Trial Court (RTC), Branch 70, Pasig City.
2. **RTC Decision on Marriage Nullity:** On January 3, 2001, the RTC declared the marriage null under Article 36 of the Family Code and ordered the liquidation of the conjugal partnership.
3. **RTC Execution Motion:** On March 7, 2003, the respondent moved for execution to implement the conjugal partnership’s liquidation, focusing on a real property in Pasig City.
4. **RTC Order for Sale:** An order on May 26, 2003, directed the sale of the property, allocating 50% of the proceeds to the common children and the rest, shared equally between the parties, minus PHP 1,500,000 owed to the petitioner.
5. **Subsequent RTC Orders:** Between July 30, 2003, and June 25, 2004, multiple orders were issued, authorizing inspection by buyers, approval of a deed of sale, and issuance of a writ of possession in favor of the buyer, BJD Holdings Corporation.
6. **Petitioner’s Opposition:** The petitioner filed several motions, including an opposition to the writ of possession, citing Article 129(9) of the Civil Code—which she claimed prioritized retaining the family home with the spouse whom most children chose to remain—but these were repeatedly denied.
7. **Court of Appeals Petition:** The petitioner filed a petition for certiorari with the Court of Appeals on October 4, 2004, challenging the RTC’s orders. The CA denied the petition on December 7, 2005, ruling in favor of the finality of the May 26, 2003 RTC decision.
8. **Supreme Court Involvement:** The petitioner moved the Supreme Court for review, arguing against the CA’s decision and related RTC orders.
**Issues:**
1. **Whether the RTC’s orders for execution, sale, and eviction contravened the finality of the January 3, 2001 decision.**
2. **Applicability of Article 129(9) of the Family Code regarding the family home—to be adjudged to the spouse with most children.**
3. **Should the property covered by Transfer Certificate of Title No. 17460 be subject to sale without considering additional conjugal property?**
4. **Is the absence of the petitioner’s consent in the deed of sale grounds for questioning the sale’s validity?**
**Court’s Decision:**
1. **Finality of RTC Orders:** The Court upheld the finality of the RTC’s May 26, 2003 order since the petitioner had already appealed unsuccessfully through G.R. No. 162745. The Supreme Court emphasized the doctrine of immutability of final judgments, and that execution orders cannot deviate from decisions already final and executory.
2. **Article 129(9) Application:** The Court cited that Article 129(9) presupposes other properties are available for division, which was not applicable as there was only one conjugal asset to distribute.
3. **Single Conjugal Property Determination:** The Court deferred to the factual findings of the RTC and CA that only one property, subject to liquidation, was part of the conjugal assets and was to be sold as per the RTC’s orders.
4. **Pending Annulment of Sale:** The pending CA case questioning the deed of sale’s validity was noted. However, this could not alter the question at hand, as determined problems of procedural lapse and certificate of approval from higher courts cemented prior rulings.
**Doctrine:**
– **Immutability of Final Judgments:** Once a decision is final, it becomes immutable and unalterable, barring the decision review’s scope.
– **Factual Findings Review:** Factual determinations by the CA and RTC, supported with substantial evidence, are generally binding and not subject for reassessment by the Supreme Court.
**Class Notes:**
– **Article 36 Family Code:** Grounds for the declaration of marriage nullity and the resulting procedural outcomes affect conjugal property settlement.
– **Article 129 Family Code:** Applicability regarding conjugal property liquidation; partition anticipates other properties.
– **Article 129(9) Family Code:** Conjugal home rules in partition, considered where multiple properties exist.
– **Rule 45 & 65 Petitions:** Outlining appropriate avenues for questioning lower court decisions and orders in Philippine judicial procedures.
**Historical Background:**
During this period, the Family Code of the Philippines was designed to protect conjugal property rights upon marriage nullity. Legal interpretations attempted to mediate between strict statutory adherence and equitable separation of property, reflecting reforms driven by modern family law principles. The decision underscored critical reading of procedural statutes aligned with judicial efficiency and clarity in post-marriage dissolution property sales.
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