Cachopero v. Celestial
G.R. No. 146754 (March 21, 2012)
Facts:
Petitioner Jesse Cachopero, along with his wife Bema Cachopero, is the younger brother of respondent Rachel Celestial. Celestial owned an old residential house situated on Lot No. 2586-G-28 in Midsayap, Cotabato, Philippines. A significant portion of this house encroached upon a 344-square meter lot (referred to as the "subject land") that was formerly part of Salunayan Creek, which had dried up due to an irrigation canal constructed by the National Irrigation Administration.
On July 21, 1989, Celestial filed an ejectment case against the spouses Cachopero, alleging that they had been living in her house without paying rent since 1973 and had refused to vacate the premises after she decided to demolish the old house due to its uninhabitable condition. On August 10, 1989, the parties entered into a Compromise Agreement, wherein the spouses agreed to vacate the premises and transfer the old house to the back of Celestial's lot within eight months, with Celestial agreeing to shoulder the expenses for the demolition and reconstruction of the house.
The Municipal Trial Court (MTC) approved the Compromise Agreement, and a judgment was rendered accordingly. However, by July 17, 1990, the Deputy Sheriff reported that the spouses had vacated Celestial's lot, but part of the house remained undemolished. Celestial subsequently filed a motion for an alias writ of execution, claiming that the terms of the Compromise Agreement had not been fully complied with.
The MTC denied Celestial's motion, stating that the agreement only required the spouses to vacate Celestial's lot, which they had done. Celestial then filed a petition for mandamus before the Regional Trial Court (RTC), seeking to compel the MTC to issue an alias writ of execution. The RTC initially dismissed the petition but later granted a motion for reconsideration, setting aside its earlier order.
The RTC conducted an ocular inspection and found that the old house had been partially demolished. However, it ultimately dismissed Celestial's petition for mandamus, stating that the issuance of an alias writ of execution depended on the outcome of another case involving the subject land, which Jesse Cachopero had applied for with the Department of Environment and Natural Resources (DENR).
Celestial appealed to the Court of Appeals, which ruled in her favor, ordering the RTC to issue an alias writ of execution for the full implementation of the compromise judgment. The spouses Cachopero then elevated the case to the Supreme Court, challenging the Court of Appeals' decision.
Issues:
- Can mandamus be used to compel the RTC to issue an alias writ of execution for a compromise agreement that has already been deemed properly executed?
- Is it lawful for the RTC to condition the execution of the compromise agreement on the outcome of a separate case regarding the subject land?
Arguments:
Petitioners (Spouses Cachopero):
- They argued that the writ of execution had been properly implemented as they had vacated Celestial's lot, which was the subject of the ejectment case.
- They contended that the RTC was correct in dismissing the mandamus petition, as the execution of the compromise agreement should not be contingent upon the outcome of the separate case regarding the subject land.
Respondent (Rachel Celestial):
- Celestial maintained that the compromise agreement was not fully executed, as part of the old house remained standing.
- She argued that the RTC's decision to condition the issuance of an alias writ of execution on the outcome of the other case was improper and constituted an abuse of discretion.
Court's Decision and Legal Reasoning:
The Supreme Court affirmed the decision of the Court of Appeals, emphasizing that a compromise judgment is immediately executory and has the force of res judicata between the parties. The Court held that the RTC had a ministerial duty to execute the compromise agreement as it was clear and unequivocal in its terms. The spouses Cachopero's argument that the execution should be contingent upon the outcome of the separate case was rejected, as the issues in the two cases were distinct.
The Court reiterated that mandamus is an appropriate remedy to compel the performance of a legal duty when there is no other adequate remedy available. It emphasized that the spouses Cachopero had not shown any supervening event that would justify staying the execution of the compromise agreement.
Significant Legal Principles Established:
- A compromise agreement, once judicially approved, has the force of res judicata and is immediately executory.
- The issuance of a writ of mandamus is appropriate to compel the execution of a compromise agreement when the terms are clear and unequivocal.
- The execution of a compromise agreement cannot be conditioned on the outcome of unrelated legal proceedings.