1.

Nature of the Dispute:

o The case began in 1984 when Natalia Realty, Inc. filed a complaint for accion publiciana
(an action to recover possession) involving two parcels of land in Sitio Banabas,
Antipolo, Rizal. These lands were covered by Transfer Certificates of Title (TCT) Nos.
31527 and 31528.

o The private respondents (Antonio Martinez, Felipe Padua, Mario Perfecto, and Hermito
Salodega) were occupying parts of the property, claiming that they had been in
possession of the land since before World War II.

2. Temporary Restraining Order:

o When the complaint was filed, the Regional Trial Court issued a temporary restraining
order (TRO) on January 30, 1984, preventing the private respondents from obstructing
Natalia Realty's work on the property.

3. Private Respondents’ Defense:

o In their answer to the complaint, the private respondents asserted ownership over their
respective homes and lots, claiming long-term possession that predated World War II.
They alleged that Natalia Realty had no right to evict them from the land.

4. Dismissal of the Complaint:

o In August 1991, the trial court (presided by Judge Senecio O. Ortille) dismissed Natalia
Realty’s complaint due to its failure to prosecute the case. Natalia Realty did not take
timely action to appeal or move for reconsideration, rendering the dismissal final and
executory.

5. Court Orders on Possession:

o In April 1992, the trial court, this time presided by Judge Sinforoso S. Nano, granted a
motion from the private respondents, ordering Natalia Realty to surrender possession of
portions of the subject property to the private respondents. Natalia Realty did not file a
timely appeal or motion for reconsideration, making this order final as well.

6. Failed Appeals:

o Natalia Realty made several attempts to appeal these decisions, but its actions were
either untimely or procedurally defective:

 In May 1992, Natalia Realty filed a motion to set aside the dismissal, citing
excusable oversight by its counsel, but this was denied by the court.

 The company filed a petition for certiorari with the Court of Appeals in 1993
(CA-G.R. SP No. 30787) but the appellate court dismissed the petition for being
filed beyond the reasonable time and noted that the trial court’s orders were
already final and executory.
  Natalia Realty’s motion for reconsideration of the appellate court's ruling was
also denied, and an entry of judgment was issued in December 1993.

7. Navarro’s Motion for Execution:

o Felipe Navarro, claiming to be the private respondents' original counsel, filed a motion
for the issuance of a writ of execution in December 1993. However, the trial court
denied Navarro’s motion in March 1994, ruling that the complaint was not a class suit
and that restoring possession to the respondents was beyond its authority following the
case dismissal.

o Further complicating matters, Navarro was later revealed to be a disbarred lawyer, and
his motion was found to be unauthorized.

8. Court of Appeals Involvement:

o Despite the disbarment of Navarro, the private respondents continued to pursue

execution of the final orders. In June 1995, the Ninth Division of the Court of Appeals
issued a resolution instructing the trial court to enforce its previous orders, including the
dismissal of Natalia Realty’s complaint and the order granting possession to the private
respondents.

9. Intervention by 359-A Multi-Purpose Cooperative:

o During the later stages of the litigation, the 359-A Multi-Purpose Cooperative, a group
that included the private respondents, attempted to intervene in the case. The
Cooperative was assigned the respondents' rights to the land through a Deed of
Transfer/Assignment. However, their motion to intervene was denied by the court,
citing that it was filed after the trial had concluded and the case had reached final
judgment.

10. Natalia Realty's Argument of a Supervening Event:

 Natalia Realty attempted to invoke the Supreme Court’s decision in Natalia Realty vs.
Department of Agrarian Reform (August 12, 1993) as a supervening event to prevent the
enforcement of the final judgments. In that case, the Court ruled that the subject property was
not covered by the Comprehensive Agrarian Reform Law (CARL), as it had been converted for
non-agricultural use before the law’s effectivity.

 The courts, however, rejected this argument, noting that the Natalia Realty vs. DAR decision
addressed agrarian reform coverage, not the issue of possession being litigated in the current
case. Moreover, this decision was already available before the appellate court's rulings in the
case became final and could not be invoked as a supervening event.

11. Supreme Court Ruling:

 The Supreme Court ultimately dismissed Natalia Realty’s petition, ruling that the orders of the
trial court and Court of Appeals were final and should be executed. The Court criticized Natalia
Realty’s repeated efforts to delay the execution of final judgments, declaring that litigation must
 end and the prevailing parties (the private respondents) must be allowed to enjoy the fruits of
their victory.

This case highlights issues of procedural delays, the importance of timely appeals, and the consequences
of a party's failure to properly prosecute its claims in court

Here are additional facts and details from G.R. No. 193945:

1. Initial Complaint and Inclusion of Defendants:

o In 1984, Remington Industrial Sales Corporation filed a complaint for a sum of money
against Marinduque Mining and Industrial Corporation (MMIC) due to MMIC's unpaid
purchases of construction materials worth ₱920,755.95.

o Over time, Remington amended its complaint to include Philippine National Bank (PNB),
Development Bank of the Philippines (DBP), Nonoc Mining and Industrial Corporation,
Maricalum Mining Corporation, and Island Cement Corporation. These entities were
included as they had acquired MMIC’s assets through foreclosure.

2. RTC Decision (1990):

o The RTC ruled in favor of Remington on April 10, 1990, holding all the defendants,
including Maricalum, jointly and severally liable for ₱920,755.95, with 10% interest per
annum, plus attorney’s fees and costs. The court determined that MMIC’s debts were
transferred to its successor entities.

3. Appeals by Defendants:

o The defendants appealed the RTC decision to the Court of Appeals (CA). In 1995, the CA
upheld the RTC's ruling. However, PNB and DBP continued their appeals to the Supreme
Court. Maricalum, though it attempted to appeal, was denied due to procedural errors,
and the ruling against it became final in January 1997.

4. Supreme Court Rulings in Related Cases:

o In separate decisions in 2001, the Supreme Court ruled in favor of PNB and DBP in their
respective cases (G.R. Nos. 122710 and 126200). The Court ruled that Remington had no
cause of action against PNB, DBP, and their successors, including Maricalum. These
entities were deemed separate from MMIC and were not liable for MMIC’s debts under
the foreclosure acquisitions.

5. Execution Against Maricalum:

o Despite these rulings, in 2001, the RTC granted Remington's motion for execution
against Maricalum, which led to the garnishment of Maricalum’s bank accounts
(₱920,755.95 with Global Bank and ₱32,256.48 with Equitable PCI Bank).

o Maricalum challenged this in a separate petition (CA-G.R. SP No. 65209) but initially lost
in 2003. However, in a 2008 decision, the Supreme Court ruled in favor of Maricalum,
 finding that the earlier dismissals of PNB and DBP’s liability extended to Maricalum as
well. This ruling annulled the execution orders issued by the RTC.

6. Restitution Claim:

o Following the Supreme Court's 2008 decision, Maricalum filed a motion for restitution
to recover the amounts garnished from its accounts. The RTC initially denied the motion,
citing the immutability of final judgments. Maricalum appealed this ruling to the CA (CA-
G.R. SP No. 110178), which reversed the RTC and ordered Remington to return the
garnished amounts, with 12% interest per annum.

7. Remington’s Arguments:

o Remington contended that the RTC’s 1990 decision had become final and executory and
that Maricalum could not escape liability due to the principle of immutability of final
judgments. It also argued that the execution had been validly enforced in 2001, long
before the supposed "supervening event."

8. CA and Supreme Court Rulings on Restitution:

o The CA ruled in favor of Maricalum, stating that the dismissal of the complaint against
PNB and DBP constituted a supervening event, effectively "blotting out" the RTC’s 1990
decision. The CA ordered Remington to restitute the garnished amounts to Maricalum.

o Remington challenged this ruling, but the Supreme Court denied the petition. The Court
agreed with the CA, affirming that the supervening events significantly changed the
rights of the parties, rendering the previous execution unjust. However, the Court
modified the interest on restitution, applying 12% interest until June 30, 2013, and 6%
thereafter, in line with new legal standards.

The case illustrates how legal principles such as the finality of judgments and supervening events can
interact in complex litigation, particularly when multiple parties and appellate decisions are involved

Here are additional facts from G.R. No. 72645:

1. Original Case and Judgment (Civil Case No. 59506):

o The original case, Luzon Surety Co., Inc. v. Material Distributors (Phil.), Inc., was filed to
recover ₱20,000 with 12% interest per annum (compounded quarterly) and ₱3,608 for
unpaid premiums and stamps on a surety bond.

o Gil Puyat, along with other defendants, was held jointly and severally liable. The
judgment became final on April 13, 1967, but was not enforced within five years, which
would have required an execution on motion.

2. Revival of the Judgment (Civil Case No. 93268):

 o In 1974, Luzon Surety filed a new case to revive the 1967 judgment. On May 24, 1974,
the Court of First Instance issued a decision reviving the original judgment with the
same terms, including the payment of ₱20,000, the 12% interest, and the ₱3,608 for
premiums.

o The revived judgment became final in 1974, but again, Luzon Surety did not take steps
to enforce the judgment within the next five years by motion.

3. Death of Gil Puyat and Claim Against His Estate:

o Gil Puyat passed away on March 28, 1981. On September 1, 1982, Luzon Surety filed a
claim against his estate, seeking to recover ₱178,507.76, including accumulated interest,
unpaid premiums, stamps, attorney’s fees, and costs.

4. Opposition by the Administrators of Gil Puyat's Estate:

o The administrators of Gil Puyat's estate opposed the claim, arguing that Luzon Surety
failed to execute the judgment against Gil Puyat during his lifetime and that the claim
had prescribed. They pointed out that no action had been taken to enforce either the
1967 or 1974 judgment within the respective prescriptive periods.

5. Trial Court’s Dismissal and Appellate Court’s Affirmation:

o The Regional Trial Court of Quezon City dismissed Luzon Surety’s claim, agreeing with
the administrators' argument that the action had prescribed. The court ruled that while
judgments may be revived once, the ten-year prescriptive period for enforcing the
revived judgment began from the finality of the original judgment in 1967.

o On appeal, the Intermediate Appellate Court affirmed the trial court's ruling. It held that
the right to enforce the judgment had already prescribed since more than 15 years had
passed since the finality of the original judgment.

6. Supreme Court's Ruling:

o The Supreme Court upheld the dismissal, ruling that the prescriptive period for
enforcing the judgment began in 1967, when the original judgment became final. The
Court emphasized that while the judgment was revived in 1974, the right to enforce it
could not extend beyond ten years from the original judgment's finality.

o The Court clarified that Luzon Surety could not file a second action to revive the
judgment after more than ten years had passed from the finality of the original 1967
judgment.

7. Prescription Defense:

o The Supreme Court also addressed the issue of whether the respondents waived their
right to invoke prescription, ruling that the defense of prescription was valid even
though it had not been raised earlier in the proceedings. The pertinent dates were part
of the petitioner’s own filings, making it clear that the action had already prescribed.
In conclusion, the case highlights the strict application of prescriptive periods for enforcing judgments.
Despite Luzon Surety’s efforts to revive the 1967 judgment, its failure to act within the ten-year period
rendered its claim against the estate of Gil Puyat unenforceable due to prescription