SPOUSES FELIPE PARINGIT AND JOSEFA PARINGIT, PETITIONERS, VS. MARCIANA PARINGIT BAJIT, ADOLIO PARINGIT, AND ROSARIO PARINGIT ORDOÑO, RESPONDENTS.

Paringit versus Bajit

The Case

This is a petition for review on certiorari brought by Spouses Felipe Paringit and Josefa Paringit against Marciana Paringit Bajit, Adolio Paringit, and Rosario Paringit Ordoño. The dispute began as a complaint for annulment of title and reconveyance of a 150 square meter lot in Manila, registered in the name of the petitioners but held, the respondents claimed, for the benefit of all the children of Julian and Aurelia Paringit. The case matters because it is a lesson on the finality of judgments: once a decision becomes final and executory, it is immutable and unalterable, and the trial court's task is merely to implement it faithfully, not to vary its terms. It is also a stern reminder that dilatory schemes against execution invite sanctions.

Procedural History

In the Regional Trial Court, Branch 39, Manila, the respondents sued their brother Felipe and his wife Josefa for annulment of title and reconveyance. The trial court ruled in favor of the petitioners and dismissed the complaint. On appeal, the Court of Appeals reversed, holding that an implied trust existed between the petitioners as trustees and the respondents as trustors, and ordered the petitioners to reconvey to the respondents their proportionate shares upon reimbursement of their shares in the purchase price plus legal interest. On the petitioners' appeal by certiorari, the Supreme Court affirmed with modification, ordering the respondents to reimburse the petitioners their corresponding share in the purchase price plus expenses advanced amounting to 60,000 pesos with legal interest from April 12, 1984 until fully paid.

After that decision became final, the trial court issued a writ of execution, but for nine years the writ remained unimplemented because of multiple motions filed by the petitioners, which the trial court invariably denied. The trial court ruled that the deed of reconveyance covers the respondents' proportionate share of the whole 150 square meter property, and later granted the respondents' motion for the appointment of a surveyor, reiterating the need to segregate the respondents' 90 square meter share from the entire 150 square meter lot. The petitioners went to the Court of Appeals on certiorari, imputing grave abuse of discretion on the trial court for allegedly altering the final decision. The Court of Appeals dismissed the petition and denied reconsideration. The petitioners then elevated the matter to the Supreme Court by petition for review on certiorari.

Facts

The lot, 150 square meters in area and situated in Manila, was leased by Julian and Aurelia Paringit from Terocel Realty, Incorporated, and served as the family home. When Terocel offered to sell the lot, the parents sought financial help from their children. Only Felipe and his wife were able to give assistance. Their father Julian executed an affidavit declaring that the lot was purchased for the benefit of all his children, namely Florencio, Marciana, Adolio, Rosario, and Felipe, subject to the condition that the first four siblings reimburse Felipe their respective shares in the purchase price.

The parents bought the property on January 30, 1984, and the family resided thereon. In 1988, the petitioners moved to another house along the same street. After their father died on December 21, 1994, the petitioners demanded that the respondents pay back rentals for their use and occupancy of the property from March 1990 to December 1995. The respondents then sued for annulment of title and reconveyance.

The Supreme Court, in its decision of September 29, 2010, affirmed the finding of an implied trust and directed the respondents to reimburse the petitioners their corresponding share in the purchase price plus expenses advanced amounting to 60,000 pesos with legal interest from April 12, 1984 until fully paid. The decision spoke of the whole 150 square meter lot. In implementing the decision, the trial court held that the deed of reconveyance covers the respondents' proportionate share of the whole property, and that the shares of Marciana, Adolio, and Rosario total 90 square meters, or 30 square meters each, to be segregated from the entire 150 square meter lot.

Issues

• Whether or not the Court of Appeals correctly ruled that when the trial court pronounced there was a need to segregate the 90 square meters from the 150 square meter lot, it actually conformed with the terms of the Supreme Court's decision dated September 29, 2010.
• Whether or not the trial court altered or varied the terms of the final and executory decision of the Supreme Court.

Applicable Provisions

The decision does not quote a specific statutory provision; it applies the doctrine of immutability of final judgments and the law on implied trusts as established in the prior decision. The dispositive portion of the September 29, 2010 decision, which the Court quotes and construes, provides:

WHEREFORE, the Court DENIES the petition, and AFFIRMS the decision of the Court of Appeals in CA-G.R. CV 84792 with the MODIFICATION that respondents Marciana Paringit Bajit, Adolio Paringit, and Rosario Paringit Ordoño reimburse petitioners Felipe and Josefa Paringit of their corresponding share in the purchase price plus expenses advanced by petitioners amounting to P60,000.00 with legal interest from April 12, 1984 until fully paid.

This dispositive portion is the source of the trial court's authority to implement the judgment, and its terms define the extent of the property to be reconveyed.

Ruling

The Court ruled in the affirmative on the first issue. The decision of September 29, 2010 speaks of the whole 150 square meter lot and nothing less. The Court quoted its earlier findings, including the following:

Here, the evidence shows that Felipe and his wife bought the lot for the benefit of Julian and his children, rather than for themselves.

The Court stressed that the decision consistently refers to the subject property as the lot, meaning its entirety, all 150 square meters and not just 110 square meters as the petitioners erroneously asserted. Consequently, when the trial court specified that the entire 150 square meters be distributed among the five siblings, Florencio, Felipe, Marciana, Adolio, and Rosario, each to get 30 square meters, it computed the numbers correctly. And when it said that the shares of Marciana, Adolio, and Rosario totaled 90 square meters, or 30 square meters each, it again computed the numbers correctly.

On the second issue, the Court held that the trial court did not alter the terms of the final decision. It merely effected a sound and logical implementation of the same. The Court also noted the petitioners' propensity for devising ways and means of delaying for almost nine years the implementation of the decision, which it characterized as contumacious disobedience. It warned that non-compliance with the lower court's order is no more than non-recognition of the Court's directive, and that the Court is not expected to yield to assaults of disrespect.

Doctrine

A decision that has acquired finality becomes immutable and unalterable. The trial court cannot vary its terms; it can only implement them faithfully. Where the final decision directs the reconveyance of a proportionate share of a lot described in its entirety, the trial court correctly computes the shares based on the whole property, not on a portion. Any action, strategy, or scheme that prolongs the implementation of a final and executory judgment constitutes contumacious disobedience and may be sanctioned. The doctrine of implied trust, as applied in the earlier decision, binds the parties: one who buys property for the benefit of another creates a trust in favor of the latter, and the trustee must reconvey the property upon reimbursement.

Disposition

The petition is denied, and the decision and resolution of the Court of Appeals are affirmed. The Regional Trial Court, Branch 39, Manila, is directed to promptly implement the decision of September 29, 2010 within ten days from notice and to submit its compliance report not later than five days from implementation of the writ of execution. The petitioners and their counsel are strictly warned against committing any further action, strategy, or scheme that will prolong the delayed implementation.

Remember This

A final and executory judgment is immutable and unalterable; the trial court may only implement it, and any dilatory scheme to defeat execution is contumacious disobedience. Examiners use this case to test the doctrine of finality of judgments and the extent of a trial court's authority in executing a final decision.