This case clarifies the process and timeline for reviving a final judgment, particularly in cases involving property disputes. The Supreme Court emphasized that an action to revive a judgment must be filed within ten years from the time the judgment becomes final. Here, the Court determined that the action to revive a forcible entry judgment was timely filed, ensuring the protection of property rights initially established in the prior ruling. This decision highlights the importance of understanding prescriptive periods and the available remedies to enforce court decisions.

Preserving Justice: How Long Can a Forcible Entry Ruling Last?

The Quesada v. Court of Appeals case revolves around a long-standing dispute over a portion of land in Iloilo. Epitacio Asuncion owned a lot, part of which was leased to Claro San Luis. Querubin Derequito, whose land was separated from Asuncion’s by the Balabag River, encroached on the leased portion by converting part of the river into a fishpond. This encroachment led to a forcible entry case filed by Derequito against San Luis, which San Luis won in 1975. Decades later, after the lease expired and Derequito’s heirs continued to occupy the land, the Quesadas (Asuncion’s successors) sought to revive the 1975 judgment to regain possession. The central legal question is whether the Quesadas’ action to revive the judgment was filed within the prescriptive period, and whether the lower court erred in awarding damages in the revival case.

The Court of Appeals ruled that the action to revive the judgment had prescribed, reasoning that more than 30 years had passed since the original decision became final. This ruling hinged on their calculation of the prescriptive period, which the Supreme Court found to be flawed. The Supreme Court emphasized that the prescriptive period for reviving a judgment is ten years from the date it becomes final and executory. The original judgment was rendered on August 25, 1975, and the motion for reconsideration was denied on September 15, 1976. Thus, the action to revive the judgment, filed on August 26, 1985, was deemed timely, falling within the ten-year period. To clarify the timeline for revival of judgements, the rules on judgements provides that:

Article 1144 of the Civil Code states that the following actions must be commenced within ten years: (1) Upon a written contract; (2) Upon an obligation created by law; (3) Upon a judgment.

The Supreme Court also addressed the Court of Appeals’ concern regarding the award of damages in the revival case. The appellate court viewed it as a modification of the original judgment, which only concerned possession. The Supreme Court clarified that the damages awarded represented the losses suffered by the Quesadas due to the Derequitos’ continued occupation of the land since 1977, when San Luis’s lease expired. The revival case had two causes of action: one to revive the original judgment, and another to recover possession and damages for the subsequent violation of the Quesadas’ property rights. Furthermore, the Court reasoned that the action filed had two purposes:

[T]o revive the judgment in the case for forcible entry, which was in favor of former lessee San Luis. The second sought the recovery of possession and damages against respondents for violation of petitioners’ right to the possession and fruits of the lot since 1977.

Procedurally, the Supreme Court noted that the Court of Appeals erred in entertaining the petition for certiorari filed by the Derequitos. Certiorari is only available when there is no plain, speedy, and adequate remedy in the ordinary course of law. The Derequitos had initially filed a notice of appeal from the trial court’s decision, but it was denied due course because it was filed late. Having lost their right to appeal, they could not resort to certiorari. The Supreme Court further stated that because respondents were already represented by counsel at the time of the first trial, it should be assumed that they were fully aware of the next actions to be taken by their legal counsel. This is founded in a legal principle which the Court acknowledged, that:

[W]hen a client is represented by counsel, notice to counsel is notice to client.

The Supreme Court found no reason to disturb the lower court’s decision. The Quesadas had successfully revived the judgment and were entitled to recover possession of their property and receive compensation for the damages caused by the Derequitos’ unlawful occupation. This case underscores the importance of adhering to procedural rules and understanding the prescriptive periods for enforcing legal rights. Here is a summary table of the differences in both Courts’ decisions:

Issue	Court of Appeals Decision	Supreme Court Decision
Prescription	Action to revive judgment had prescribed.	Action to revive judgment was timely filed.
Damages	Awarding damages was a modification of the original judgment.	Damages were justified due to continued unlawful occupation.
Certiorari	Petition for certiorari was granted.	Petition for certiorari should not have been entertained due to the availability of appeal.

FAQs

What was the key issue in this case?	The main issue was whether the action to revive a judgment for forcible entry was filed within the prescriptive period of ten years. The Court also questioned the propriety of the appellate court granting certiorari when appeal was available.
What is the prescriptive period for reviving a judgment?	The prescriptive period is ten years from the date the judgment becomes final and executory, according to Article 1144 of the Civil Code. The countdown starts upon final judgement of a case.
Why did the Court of Appeals rule against reviving the judgment?	The Court of Appeals incorrectly calculated the prescriptive period, believing that more than 30 years had passed since the original judgment. However, the Supreme Court rectified that the Court of Appeals’ timeline included the promulgation of their own decision in consideration, hence rendering an improper and false judgement on the prescriptive period.
Why did the Supreme Court disagree with the Court of Appeals’ decision?	The Supreme Court found that the action was timely filed and that the award of damages was justified due to the continued unlawful occupation of the land. Furthermore, the procedural requirements were not fully addressed, and remedies provided under the Rules of Court were not exhausted by the petitioner prior to claiming grave abuse of discretion in their favor.
What is certiorari, and why was it improperly used in this case?	Certiorari is a remedy available when there is no appeal or other adequate remedy. In this case, the respondents had initially filed a notice of appeal, making certiorari an inappropriate remedy.
What was the basis for awarding damages in the revival case?	The damages were awarded to compensate the Quesadas for the losses they incurred due to the Derequitos’ continued occupation of the land after San Luis’s lease expired. The damages that they incurred were deemed due to their own continued defiance and refusal to vacate the premises.
What is the significance of notice to counsel in legal proceedings?	Notice to counsel is considered notice to the client, meaning that the respondents were deemed aware of the proceedings through their lawyer. This is provided that there is a document presented attesting to their legal representation and authority.
What were the two causes of action in the Quesadas’ complaint?	The complaint had two causes of action: to revive the original judgment for forcible entry and to recover possession and damages for the continued violation of their property rights. It should be noted that causes of action are often determined on a case to case basis.

The Quesada v. Court of Appeals decision reaffirms the importance of understanding and adhering to legal timelines for enforcing judgments. It underscores that property rights, once established in court, can be protected through timely action. It is further supported that due to their counsel and their counsel’s participation on their behalf, that the parties in question had full knowledge of the actions and cases filed at the time.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Conrado Quesada, et al. v. Hon. Court of Appeals, et al., G.R. No. 177516, March 13, 2009