GR 137884; (March, 2008) (Digest)
G.R. No. 137884 ; March 28, 2008
THE INSULAR LIFE ASSURANCE COMPANY, LTD., Petitioner, vs. TOYOTA BEL-AIR, INC., Respondent.
FACTS
Insular Life filed an unlawful detainer case against Toyota Bel-Air after the latter refused to vacate the leased premises upon the contract’s expiration. The Metropolitan Trial Court (MeTC) ruled in favor of Insular Life, ordering Toyota to vacate and to pay “reasonable compensation at the rate of ₱585,640.00 a month until possession…is surrendered.” Both parties initially appealed but later withdrew their notices. The MeTC then issued a Writ of Execution which, in its preamble, stated Toyota was to recover the sum “from April 15, 1997″—a specific start date not found in the dispositive portion of the decision. The sheriff levied Toyota’s properties based on this writ.
Toyota filed a Petition for Certiorari with the Regional Trial Court (RTC), arguing the writ amended the judgment by inserting the retroactive date. The MeTC subsequently issued a clarificatory order, but the RTC proceeded to rule on the certiorari petition.
ISSUE
Whether the Regional Trial Court correctly nullified the Writ of Execution issued by the Metropolitan Trial Court for being void.
RULING
Yes, the Supreme Court affirmed the RTC’s decision nullifying the writ. A writ of execution must conform strictly to the dispositive portion of the decision it seeks to enforce; it cannot modify, expand, or alter the terms of the judgment. The MeTC’s dispositive portion ordered payment from an unspecified time “until possession is surrendered.” By inserting the phrase “from April 15, 1997” in the writ’s preamble, the MeTC effectively modified the final judgment, prescribing a specific commencement date for the monetary award that was not decreed in the decision. This constituted a grave abuse of discretion, rendering the writ void.
The Court rejected Insular Life’s argument that the date was implied from the complaint’s allegations and the decision’s body. The rule is settled that execution must be based on the dispositive portion (fallo) of the decision, not on the body of the text. The subsequent clarificatory orders issued by the MeTC could not validate a void writ. Since the writ was null, all proceedings emanating from it, including the levy on Toyota’s properties, were also void. The RTC, in the exercise of its certiorari jurisdiction, correctly struck down the void writ.