**Facts:**
1. **Ownership and Cultivation**:
– Rufina Camino and Pastor Eco owned a 10.7791-hectare parcel of land.
– Spouses Fermin Bobis and Emilia Guadalupe cultivated the land.
2. **Initial Lawsuit**:
– Alfonso Ortega filed Civil Case No. 273 against Camino, Eco, Bobis, and Guadalupe demanding possession of half the planted portion or P1,650 for improvements on July 25, 1950.
3. **Compromise Agreement**:
– On August 16, 1950, parties agreed:
1. Camino and Eco would pay Ortega P140 for improvements by February 28, 1951.
2. Ortega had no other claims against defendants.
3. Ortega recognized the absolute ownership of defendants over the land.
4. Ortega renounced further damage claims.
4. **Land Transfer**:
– On August 26, 1950, Camino and Eco sold the land to Bobis and Guadalupe; a new title (TCT No. T-838) was issued in their name.
5. **Court Approval of Compromise**:
– On January 22, 1951, the court approved the aforementioned compromise agreement.
6. **Default on Payment**:
– On the due date, only P50 was paid leading to a shortfall.
– Consequently, on July 18, 1951, the court issued a writ of execution against all defendants including Bobis and Guadalupe.
7. **Execution and Sheriff’s Sale**:
– Bobis and Guadalupe contested their inclusion in the writ but their motion was denied.
– The land was sold on September 3, 1951, to Zosimo Rivera, the highest bidder.
8. **Ownership and Eviction Efforts**:
– Emilio Guadalupe failed to redeem the property or vacate it, leading to contempt proceedings and imprisonment.
– The property sale was approved, and a deed of sale issued on March 23, 1953, Zosimo Rivera sought and obtained a writ of possession.
9. **New Lawsuit for Annulment**:
– On March 4, 1960, Bobis and Guadalupe filed for annulment of the sheriff’s deed of sale, claiming the writ did not conform to the judgment.
– The trial court dismissed the complaint on June 3, 1964, resulting in an appeal.
10. **Appeal and Elevation to Supreme Court**:
– Bobis and Guadalupe contended error by the trial court in several facets including validating the sheriff’s sale and denying damages.
– The Court of Appeals elevated the case to the Supreme Court citing that only legal questions were involved.
**Issues:**
1. Was the writ of execution void as it included Bobis and Guadalupe who were not adjudged liable?
2. Should the execution sale conducted by the sheriff be annulled due to the void writ?
3. Was there any fraud in the sale of land from Camino and Eco to Bobis and Guadalupe?
4. Should damages be awarded to Bobis and Guadalupe for the wrongful execution and sale?
**Court’s Decision:**
1. **Validity of Execution Writ**:
– The Supreme Court held the writ was void concerning Bobis and Guadalupe, as they were absolved from liability and not part of the judgment payees.
– The writ unlawfully extended the judgment to them.
2. **Execution Sale**:
– Since the writ of execution was void, the subsequent sheriff’s sale was deemed null and void.
– Rivera acquired no legal title from this void sale, invalidating his acquisition.
3. **Fraud Allegation Rejection**:
– The Supreme Court found no evidence of fraud in the land sale to Bobis and Guadalupe.
– The sale price inadequacy and timing were not sufficient to prove fraud.
– Fraud must be proven with clear evidence, which was absent in the case.
4. **Denial of Damages Claim**:
– The court ruled that the sheriff acted under a court order, hence was not liable for damages.
– Damages from Rivera were also denied as the acquisition defect lay in the writ.
**Doctrine:**
1. **Conformity to Judgment**:
– Court writs must strictly conform to the judgments they execute and cannot impose additional liabilities.
– Any execution not aligning with the judgment is void.
2. **Nullity from Void Writs**:
– Any legal actions derived from a void writ, including sales, are also void.
– Rights acquired through a void process are legally nullified.
3. **Proof of Fraud**:
– Fraud allegations require clear and compelling evidence to be valid in court.
– Assumptions or circumstantial flags (like inadequate consideration or timing) without evidence don’t suffice.
**Class Notes:**
– **Key Elements in Execution and Fraud Cases**:
– **Execution Conformity**: Execution must exactly match the judgment. Any extension is void.
– **Sequential Void Nature**: Derivative actions from void writs (sales, transfers) are void.
– **Proof of Fraud**: Requires clear evidence of intentional deceit causing legal harm.
**Historical Background:**
– The case typifies issues of wrongful inclusion in execution writs and property rights’ protection.
– Reflects mid-20th century Philippine jurisprudence balancing procedural accuracy and substantive rights.
– Illuminates the judiciary’s role in rectifying overreach in writs and preserving due process.
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