[G.R. No.
223610 July 24, 2017]
Conchita S. Uy, and heirs of Jaime Uy, petitioner
vs.
Crispulo del Castillo, substituted by his heirs, respondent
Facts: Respondent heirs of del Castillo filed Quieting of Title against Jaime
Uy for a parcel of land. When Jaime Uy died, del Castillo impleaded Jamie's
children as defendants. The Regional Trial Court rendered a Decision in
favor of del Castillo, after which a writ of execution, upon motion of
respondent's. This Decision of the Court has attained finality.
Heirs of Jaime contended that the writ was void because they were held
personally liable with their separate property for Jamie's liability and that
respondents should have filed a claim against Jamie's estate in accordance
with Section 20 of Rule 3 of the Rules of Court.
Issue: Whether or not Rule 3, Section 20 of the said Rule is applicable in
this case
Ruling: No. Section 20 of Rule 3 of the Rules of Court applies in cases
where the defendant dies while the case is pending and not before the case
was even filed in Court.
Records show that Jaime Uy died six (6) years prior to the filing of the
quieting of title case. It was only found out upon Answer of his wife,
Conchita Uy, informing the RTC of the circumstances which led to the
amendment of the Information impleading his children.
Further, the issue should have been raised at the earliest opportunity and
time and again, the Court has repeatedly upheld that a decision that has
acquired finality becomes immutable and unalterable, and may no longer be
modified in any respect, even if the modification is meant to correct
erroneous conclusions of fact and law, and whether it be made by the court
that rendered it or by the Highest Court of the land.
However, the Court ruled that despite the fact that Uy siblings may be held
answerable to monetary awards in the Quieting of Title Case, such liability
cannot exceed whatever value they inherited from their late father.
