G.R. No. 156850 ; October 24, 2008
National Housing Authority, petitioner, vs. Perico V. Jao, representing the estate of the late Spouses Andrea and Ignacio Jao Tayag, respondents.

FACTS

On July 28, 1982, the National Housing Authority (NHA) filed an expropriation case against the property of Spouses Ignacio and Andrea Jao Tayag in Tondo, Manila, covering 1,660.60 square meters. The NHA deposited ₱66,400 with the Philippine National Bank (PNB). The trial court issued a writ of possession on December 29, 1982, and the NHA took possession on March 10, 1983. On March 30, 1984, the trial court upheld the NHA’s right to expropriate and set just compensation at ₱66,400. The title was canceled and a new one issued in the NHA’s name. For over 15 years, the NHA abandoned the property, failed to pay just compensation, did not develop it for any public purpose, and allowed squatters to occupy and destroy improvements. On May 20, 1997, Perico V. Jao, representing the estate, filed a case for recovery of possession and damages. The trial court ruled in favor of Jao on September 4, 1998, ordering the NHA to reconvey the property, pay monthly compensation of ₱10,000 for loss of use, ₱500,000 for damages to improvements, ₱20,000 attorney’s fees, and costs. The NHA’s appeal to the Court of Appeals was dismissed for failure to pay docket fees, and the dismissal became final and executory on March 9, 2000. Jao moved for a writ of execution, which the trial court granted. The NHA filed a motion to quash, arguing damages should be limited to the ₱66,400 deposit, but the trial court denied it. The NHA then filed a petition for certiorari with the Court of Appeals, which dismissed it, prompting the NHA to elevate the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s orders denying the motion to quash the writ of execution and notice of garnishment, which enforced a final and executory judgment ordering reconveyance of the expropriated property and payment of damages exceeding the initial deposit.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision and Resolution. The Court held that the trial court’s September 4, 1998 Order had become final and executory on March 9, 2000, as evidenced by an Entry of Judgment. A final and executory order can no longer be disturbed, regardless of any error, as judicial errors should be corrected through appeal, not through repeated suits. The Court emphasized that it could not amend a final and executory order by ruling that damages were limited to the ₱66,400 deposit, as doing so would violate settled rules on finality of judgments.