vs. JIMMY F. FLORES, EDNA F. FLORES, DANILO FLORES, BELINDA FLORES, HECTOR. FLORES, MARITES FLORES, HEIRS OF MARIA F. FLORES, JACINTO FAYLONA, ELISA FAYLONA MAGPANTAY, MARIETTA FAYLONA CARTACIANO, and HEIRS of TOMASA BANZUELA VDA. DE FAYLONA, Respondents. G.R. No. 160786, June 17, 2013
In Simplicia O. Abrigo and Demetrio Abrigo vs. Jimmy F. Flores,
et al., G.R. No. 160786, June 17, 2013,the Supreme Court stated: “[A] supervening event is an exception to the execution as a matter of right of a final and immutable judgment rule, only if it directly affects the matter already litigated and settled, or substantially changes the rights or relations of the parties therein as to render the execution unjust, impossible or inequitable. A supervening event consists of facts that transpire after the judgment became final and executory, or of new circumstances that develop after the judgment attained finality, including matters that the parties were not aware of prior to or during the trial because such matters were not yet in existence at that time. In that event, the interested party may properly seek the stay of execution or the quashal of the writ of execution, or he may move the court to modify or alter the judgment in order to harmonize it with justice and the supervening event.” HERNAN C. DALIDA, petitioner, vs. SPOUSES ELISEO NAGUIT and ALICIA NAGUIT, respondents. G.R. No. 170083, June 29, 2007
In Dalida vs. Naguit, the Supreme Court ruled:
“[T]he court may stay immediate execution of a judgment where supervening events bring about a material change in the situation of the parties which makes the execution inequitable, or where there is no compelling urgency for the execution because it is not justified by the prevailing circumstances.”
MERCURY DRUG CORPORATION AND ROLANDO J. DEL
ROSARIO, Petitioners, v. SPOUSES RICHARD Y. HUANG & CARMEN G. HUANG, AND STEPHEN G. HUANG, Respondents. G.R. No. 197654, August 30, 2017 LEONEN, J.:
In Mercury Drug Corporation and Rolando J. Del Rosario vs. Sps.
Richard and Carmen Huang, and Stephen Huang the Supreme Court extensively discussed supervening events as an exception to the doctrine of immutability of judgments, to wit: “The happening of a supervening event is likewise a ground to set aside or amend a final and executory judgment.
This exception was explained in Natalia
Realty, Inc. v. Court of Appeals, thus:
One of the exceptions to the principle of
immutability of final judgments is the existence of supervening events. Supervening events refer to facts which transpire after judgment has become final and executory or to new circumstances which developed after the judgment has acquired finality, including matters which the parties were not aware of prior to or during the trial as they were not yet in existence at that time. Parties must establish two (2) conditions in order to properly invoke the exception on supervening events. First, the fact constituting the supervening event must have transpired after the judgment has become final and executory. It should not have existed prior to the finality of the judgment. Second, it must be shown that the supervening event affects or changes the substance of the judgment and renders its execution inequitable.”
In Mercury Drug Corp., the Supreme Court also mentioned several
cases where supervening event was applied as an exception to the doctrine of immutability of judgment as follows:
“In Roman Catholic Archbishop of Caceres v.
Heirs of Manuel Abella, a civil case for quieting of title was considered as a supervening event that rendered a previous case for forcible entry unenforceable through execution. This Court held that the judgment in the case for quieting of title is a "new circumstance which developed after the finality of the judgment in the forcible entry [case] . . . [which] conclusively resolved the issue of ownership over the subject land, and the concomitant right of possession[.]" The execution of the judgment in the forcible entry case would, therefore, be unjust and inequitable to the respondents "who had been conclusively declared the owners and rightful possessors of the disputed land."
Bani Rural Bank. Inc. v. De Guzman is another
instance where the exception was applied. The development of strained relations between the employer and the employee was considered as a supervening event that rendered the execution of the judgment, ordering the reinstatement of the employee, impossible.”
The Supreme Court, in Mercury Drug Corp. further discussed the
applicability of supervening events, viz: “[S]everal cases have also been excluded from the application of the doctrine of immutability of judgment in the interest of substantial justice. The exception sometimes applied when a party's liberty is involved or when there are special and compelling circumstances. For instance, judgments of conviction that have attained finality were modified to correct an erroneous penalty previously imposed.
Judgments may also be modified or amended to
supply operational matters that are deemed necessary to carry out the decision into effect.”