The Supreme Court has affirmed that once a court decision becomes final and executory, it cannot be altered by lower courts or implementing officers like sheriffs. Attempts to modify or expand the terms of a final judgment, especially concerning monetary awards against the government, are invalid. This ruling underscores the importance of adhering strictly to the original terms of a final judgment to maintain the stability and integrity of the judicial process, while safeguarding public funds.

Reclaiming Justice: Can a Sheriff Inflate a Final Judgment Against the Republic?

This case, Atty. Romeo G. Roxas v. Republic Real Estate Corporation, stems from a long-standing dispute over a reclamation agreement between Republic Real Estate Corporation (RREC) and Pasay City. The core legal question revolves around whether a sheriff can unilaterally increase the monetary award in a writ of execution beyond what was originally decreed by the Supreme Court in a final and executory decision.

The roots of this case trace back to 1959 when RREC and Pasay City entered into an agreement for the reclamation of foreshore lands along Manila Bay. This agreement, however, was challenged by the Republic of the Philippines, leading to a protracted legal battle that eventually reached the Supreme Court in Republic v. Court of Appeals. The Supreme Court declared the reclamation agreement null and void. Despite this, the Court recognized RREC’s partial work and awarded compensation based on quantum meruit, pegging the reasonable value of services at P10,926,071.29, plus interest.

This decision became final and executory. However, subsequent attempts were made by RREC and Pasay City to modify or clarify the judgment, all of which were denied by the Supreme Court. Undeterred, RREC continued to pursue the matter, eventually leading to a writ of execution issued by the Regional Trial Court. Sheriff Reyner S. De Jesus then issued a Notice of Execution and Notice to Pay, demanding an astounding P49,173,064,201.17 from the Republic. This amount was based on the sheriff’s computation, which significantly inflated the original award through compounding interests and an adjustment for the present-day value of the peso.

The Republic challenged this Notice, arguing that it exceeded the scope of the Supreme Court’s final judgment. The Court of Appeals agreed, nullifying the writ of execution and the sheriff’s notice. This prompted Atty. Romeo G. Roxas, RREC’s former counsel, to file a petition before the Supreme Court, questioning the Court of Appeals’ decision and asserting his continued representation of RREC. RREC itself also filed a separate petition, seeking a much larger judgment award and contesting Pasay City’s share in the original compensation.

The Supreme Court addressed several key issues. First, it emphasized that the case was premature, as RREC had not first brought its money claim before the Commission on Audit (COA), as required by law. The Court cited Administrative Circular No. 10-2000 and Commission on Audit Circular No. 2001-002, which govern the issuance of writs of execution to satisfy money judgments against government agencies. These regulations mandate that all money claims against the government must first be filed with the COA for proper evaluation and settlement.

Building on this procedural point, the Court underscored the principle that public funds cannot be disbursed without a corresponding appropriation law or specific statutory authority. To ensure fiscal responsibility and prevent the disruption of essential government functions, all claims against the government must undergo scrutiny by the COA before any execution can take place.

The Supreme Court affirmed the Court of Appeals’ decision, reiterating that its prior ruling in Republic v. Court of Appeals was final and executory. The Court stated in no uncertain terms,

“[T]his Court’s decision cannot be amended by the trial court or the sheriff. Absent an order of remand, we cannot allow attempts to adjust or vary the terms of the judgment of this Court.”

This principle is rooted in the doctrine of res judicata, which prevents the relitigation of issues that have already been decided by a competent court.

The Court also rejected RREC’s argument that it was entitled to a larger share of the monetary award, excluding Pasay City. It held that the phrase “share and share alike” in the dispositive portion of the decision clearly meant that both RREC and Pasay City were to receive equal shares of the compensation. The Court invoked the plain-meaning rule (verba legis) in statutory construction, emphasizing that when the words of a law or judgment are clear and unambiguous, they should be applied literally.

The Supreme Court addressed Atty. Roxas’ attempt to continue representing RREC, despite being terminated as counsel. The Court stated that there is no such thing as an irrevocable attorney-client relationship. A client has the right to discharge their attorney at any time, with or without cause. The Court also pointed out that Atty. Roxas’ pursuit of the case, despite his termination and RREC’s express opposition, constituted a conflict of interest and a violation of his fiduciary duties as a lawyer.

Finally, the Supreme Court addressed the sheriff’s actions in inflating the judgment award. The Court emphasized that a sheriff’s duty in executing a judgment is purely ministerial, requiring strict adherence to the terms of the court’s order. A sheriff cannot unilaterally modify or expand the judgment based on their own interpretation or computation. The Court referred Sheriff De Jesus’ actions to the Office of the Court Administrator for investigation.

The Supreme Court’s decision underscores the sanctity of final judgments and the limitations on the power of lower courts and implementing officers to alter or expand those judgments. It reinforces the importance of adhering to established procedures for pursuing money claims against the government, particularly the requirement of first seeking settlement from the Commission on Audit.

This ruling serves as a reminder that the judicial process must be respected and that attempts to circumvent or undermine final decisions will not be tolerated. It also highlights the ethical obligations of lawyers to act in the best interests of their clients and to avoid conflicts of interest.

FAQs

What was the key issue in this case?	The central issue was whether a sheriff could unilaterally increase the monetary award in a writ of execution beyond what was originally decreed by the Supreme Court in a final and executory decision.
What is quantum meruit?	Quantum meruit is a legal principle that allows a party to recover compensation for services rendered or work done, even in the absence of a valid contract. The compensation is based on the reasonable value of the services provided, preventing unjust enrichment.
What is res judicata?	Res judicata is a doctrine that prevents the relitigation of issues that have already been decided by a competent court in a final and executory judgment. It promotes judicial efficiency and stability by preventing endless cycles of litigation.
What is the plain-meaning rule (verba legis)?	The plain-meaning rule, or verba legis, is a principle of statutory construction that states that when the words of a law or judgment are clear and unambiguous, they should be applied literally. It emphasizes the importance of interpreting legal texts based on their ordinary and natural meaning.
What is champerty?	Champerty is an agreement where a person without prior connection to a lawsuit provides funds to pursue it in return for a portion of the judgment if successful. Such agreements are often deemed against public policy as they can incentivize frivolous litigation.
What is a sheriff’s role in executing a judgment?	A sheriff’s role in executing a judgment is purely ministerial. They are required to strictly adhere to the terms of the court’s order and cannot unilaterally modify or expand the judgment based on their own interpretation or computation.
Why was it important for RREC to first bring its claim to the COA?	RREC needed to bring its claim to the COA because all money claims against the government must first be filed with the COA for evaluation and settlement, as mandated by Administrative Circular No. 10-2000 and Commission on Audit Circular No. 2001-002. This ensures fiscal responsibility and prevents the disruption of essential government functions.
Can a client terminate their attorney-client relationship at any time?	Yes, a client has the right to discharge their attorney at any time, with or without cause. This is based on the principle that the attorney-client relationship is highly fiduciary and requires the client’s trust and confidence.
What was the consequence for Sheriff De Jesus’ actions?	The Supreme Court referred Sheriff De Jesus’ actions in inflating the judgment award to the Office of the Court Administrator for investigation. This highlights the importance of sheriffs adhering strictly to the terms of court orders and avoiding any actions that could compromise the integrity of the judicial process.

This case clarifies the limits of judicial authority post-judgment and reinforces the importance of fiscal responsibility in claims against the government. Parties seeking to enforce judgments must adhere to established procedures and cannot unilaterally alter the terms of a final and executory decision. Furthermore, the ethical obligations of legal representation require attorneys to act in their client’s best interests and respect the client’s right to terminate the relationship.

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: Atty. Romeo G. Roxas v. Republic Real Estate Corporation, G.R. No. 208205, June 01, 2016