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Tag: Satisfaction of Judgment

  • Conditional Compromise: Satisfaction of Judgment and the Mootness Doctrine in Labor Disputes

    The Supreme Court ruled that a Satisfaction of Judgment, which appears to settle a labor dispute, does not automatically render a pending appeal moot if the agreement stipulates that the payment is without prejudice to the appellate proceedings and requires the employee to return the payment if the employer prevails on appeal. This decision clarifies the impact of conditional settlements on ongoing legal challenges, ensuring that parties can pursue appeals without forfeiting their rights. This ensures fairness and allows for judicial review on the merits of the case, even after initial settlement attempts.

    When ‘Settled’ Isn’t Final: Can an Agreement Be Both a Resolution and a Placeholder?

    Philippine Transmarine Carriers, Inc. (PTCI) hired Cesar C. Pelagio as a Motorman. Pelagio experienced health issues and was repatriated. Conflicting medical assessments arose regarding his disability, leading to a labor dispute. The Labor Arbiter (LA) initially ruled in favor of Pelagio for a partial disability. However, the National Labor Relations Commission (NLRC) reversed this decision, awarding him total disability benefits. PTCI appealed to the Court of Appeals (CA). During the appeal, PTCI paid Pelagio, executing a Satisfaction of Judgment that stated the payment was “without prejudice” to their pending appeal. The CA then dismissed PTCI’s appeal, stating that the Satisfaction of Judgment rendered the case moot. This prompted PTCI to elevate the case to the Supreme Court, questioning whether the CA erred in dismissing the appeal based on the compromise agreement.

    The Supreme Court addressed whether the CA correctly dismissed the certiorari petition based on the compromise agreement between the parties. The central issue was whether the Satisfaction of Judgment rendered the certiorari proceedings before the CA moot. To resolve this, the Court examined the nature of compromise agreements and their effect on pending litigation, particularly when such agreements contain conditions. A compromise agreement is a contract where parties make reciprocal concessions to avoid or end litigation, governed by contract law principles. The Court emphasized that a valid compromise agreement has the effect of res judicata, making a pending case moot. However, parties can include clauses that prevent a case from becoming moot, such as when the agreement is made without prejudice to the final disposition of the case. Such modifications must not violate law, morals, good customs, public order, or public policy, per Article 2028 of the Civil Code.

    The Supreme Court, in analyzing the agreement between PTCI and Pelagio, noted critical elements. The Satisfaction of Judgment stated that PTCI had paid Pelagio P3,313,772.00 to satisfy the NLRC ruling. Crucially, this payment was explicitly “without prejudice” to PTCI’s pending appeal before the CA. Pelagio acknowledged that the payment was made to prevent imminent execution of the NLRC ruling and agreed to reimburse PTCI if the CA reversed the NLRC judgment. The Court referred to previous rulings, including Leonis Navigation Co., Inc. v. Villamater, where a similar agreement did not render the case moot because the employee was estopped from claiming the controversy had ended due to the acknowledgment receipt stating that the payment was without prejudice to the pending appeal.

    The Court also addressed an apparent contradiction with its ruling in Career Philippines Ship Management, Inc. v. Madjus. In Career Philippines, a “conditional settlement” was interpreted as an amicable settlement, rendering the certiorari petition moot. The Court clarified this discrepancy by referring to Philippine Transmarine Carriers, Inc. v. Legaspi, which reconciled the conflicting pronouncements. The Court explained that the ruling in Career Philippines was based on the fact that the agreement was highly prejudicial to the employee, preventing them from pursuing further claims while allowing the employer to continue their appeal. In contrast, the agreement in Leonis Navigation was fair to both parties, allowing each to pursue available legal remedies.

    Applying these principles to the case at hand, the Supreme Court emphasized the absence of any clause prohibiting either party from seeking further redress. The agreement explicitly stated that the payment was without prejudice to the outcome of the certiorari proceedings. This meant that both PTCI and Pelagio could pursue available legal remedies depending on the CA’s ruling. The Court found that the agreement between PTCI and Pelagio was fair and not prejudicial to either party. Therefore, it did not render the certiorari proceedings moot. Because the CA’s dismissal was not based on the merits of the case, the Supreme Court deemed it appropriate to remand the case to the CA for further proceedings. The Supreme Court held that the CA erred in dismissing the certiorari petition based on the compromise agreement. Thus, the Court granted the petition, reversing and setting aside the CA’s decision and resolution, and reinstating the case to the CA for resolution on its merits.

    FAQs

    What was the key issue in this case? The key issue was whether a Satisfaction of Judgment, executed during an appeal, rendered the case moot when the agreement stated that the payment was without prejudice to the appellate proceedings.
    What is a Satisfaction of Judgment? A Satisfaction of Judgment is a document confirming that a judgment has been fully paid and satisfied. It typically signals the end of legal proceedings related to that judgment.
    What does “without prejudice” mean in this context? “Without prejudice” means that the payment and the agreement do not waive any rights or claims that the parties may have in the ongoing legal proceedings. It preserves their ability to continue the appeal.
    How did the Court of Appeals rule? The Court of Appeals dismissed the petition for certiorari, ruling that the Satisfaction of Judgment was a compromise agreement that rendered the issues moot and academic.
    What was the Supreme Court’s decision? The Supreme Court reversed the Court of Appeals’ decision, holding that the conditional Satisfaction of Judgment did not render the case moot because it was made without prejudice to the pending appeal.
    What is the significance of this ruling? This ruling clarifies that parties can pursue appeals even after a settlement, provided the settlement explicitly reserves their right to continue the appeal and provides a mechanism for restitution if the appeal is successful.
    How does this ruling affect labor disputes? It provides clarity on the impact of settlement agreements on ongoing appeals, ensuring that employers and employees can enter into settlements without automatically forfeiting their rights to appeal adverse decisions.
    What should parties consider when drafting settlement agreements? Parties should clearly state whether the agreement is intended to resolve all issues definitively or whether it is without prejudice to ongoing appeals. They should also include provisions for restitution if the appeal is successful.

    In conclusion, the Supreme Court’s decision underscores the importance of clearly defined terms in settlement agreements, especially when appellate proceedings are pending. The ruling ensures that parties can pursue legal remedies without the risk of losing their rights due to conditional settlements. This balances the need for efficient dispute resolution with the right to judicial review.

    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: Philippine Transmarine Carriers, Inc. vs. Cesar C. Pelagio, G.R. No. 211302, August 12, 2015

  • Satisfaction of Judgment and the Right to Appeal: Navigating Mootness in Philippine Labor Law

    The Supreme Court has clarified that the satisfaction of a judgment award, particularly when compelled by a writ of execution, does not automatically render a pending appeal moot, especially when the payment is made without prejudice to further legal recourse. This ruling ensures that employers are not penalized for complying with labor court orders while simultaneously preserving their right to challenge those orders on appeal. It balances the need to compensate employees promptly with the employer’s right to seek judicial review, ensuring fairness and due process in labor disputes.

    Can Compliance Be Held Against You? Examining Mootness in Labor Disputes

    This case revolves around a claim for permanent disability compensation filed by Mauricio G. Picar, Jr., a seafarer, against Seacrest Maritime Management, Inc., Rolando B. Magcale, and Sealion Shipping Limited – United Kingdom. After Picar obtained a favorable judgment from the Labor Arbiter (LA), which was affirmed by the National Labor Relations Commission (NLRC), the employer, Seacrest Maritime, elevated the matter to the Court of Appeals (CA). While the case was pending in the CA, Picar sought execution of the LA decision, leading to the employer’s payment of the judgment award. Subsequently, the CA dismissed the employer’s petition, deeming it moot and academic due to the satisfaction of the judgment. This decision prompted the employer to seek recourse before the Supreme Court, questioning whether compliance with a writ of execution should negate their right to appeal.

    The central legal question before the Supreme Court was whether the CA erred in dismissing the petition for certiorari based on the premise that the employer’s satisfaction of the judgment award rendered the case moot. The employer argued that the payment was involuntary, compelled by a writ of execution, and explicitly made without prejudice to their pending appeal. The seafarer, on the other hand, contended that the employer’s voluntary satisfaction of the judgment indicated their acceptance of the award’s merits, thus justifying the CA’s dismissal.

    The Supreme Court, in resolving this issue, underscored the principle that compliance with a writ of execution does not automatically signify an abandonment of one’s right to appeal. Building on this principle, the Court distinguished the present case from Career Philippines Ship Management, Inc. v. Madjus, a case relied upon by the CA. In Career Philippines, the settlement was deemed an amicable agreement, precluding further legal action. The Supreme Court emphasized that in the case at bar, there was no such amicable settlement or voluntary agreement that would indicate a waiver of the employer’s right to appeal. Instead, the payment was a direct result of a writ of execution, compelling the employer to satisfy the judgment while preserving their right to challenge it in a higher court.

    The Court also cited Leonis Navigation v. Villamater, highlighting that a petition for certiorari before the CA is not rendered moot and academic merely because of the finality of the case at the lower levels. The Court elucidated that a petition for certiorari under Rule 65 of the Rules of Court allows for judicial review of NLRC decisions, provided it is filed within the prescribed 60-day period. Furthermore, the Court clarified that a certiorari petition focuses on errors of jurisdiction or grave abuse of discretion, rather than an evaluation of the evidence’s correctness.

    Moreover, the Supreme Court referenced Philippine Transmarine Carriers, Inc. v. Legaspi to further solidify its stance. In Transmarine, the Court held that the satisfaction of a monetary award does not render a petition for certiorari moot, especially when the settlement is made without prejudice to the pending appeal and includes an agreement for the return of the payment if the appeal is successful. It emphasized the importance of ensuring that settlements are fair to both parties and that neither party is unduly prejudiced by the agreement.

    The ruling in the present case aligns with the principles of fairness and due process, ensuring that employers are not penalized for complying with legal obligations while preserving their right to seek judicial review. This approach contrasts with a strict interpretation of mootness, which could discourage compliance and prolong legal disputes. By allowing employers to satisfy judgments without forfeiting their right to appeal, the Court promotes a more balanced and equitable resolution of labor disputes.

    The implications of this decision extend beyond the immediate parties involved. It provides clarity and guidance for employers and employees navigating labor disputes, particularly in situations where a judgment award is subject to appeal. The ruling underscores the importance of clearly defining the terms of any settlement or payment, ensuring that the parties’ rights and obligations are explicitly stated. This will help prevent future disputes over whether a payment constitutes a waiver of the right to appeal.

    Furthermore, this case highlights the delicate balance between enforcing labor rights and protecting the right to judicial review. While it is essential to ensure that employees receive timely compensation for their claims, it is equally important to safeguard the employer’s right to challenge adverse rulings. The Supreme Court’s decision strikes a reasonable balance between these competing interests, promoting a fair and efficient resolution of labor disputes.

    FAQs

    What was the key issue in this case? The key issue was whether an employer’s compliance with a writ of execution to satisfy a judgment award rendered their pending appeal moot and academic. The Supreme Court clarified that it does not, especially when the payment is made without prejudice to the appeal.
    What is a writ of execution? A writ of execution is a court order directing a law enforcement officer to enforce a judgment, typically by seizing assets or property to satisfy the debt owed. In this context, it compelled the employer to pay the judgment award to the seafarer.
    What does “moot and academic” mean in legal terms? A case is considered moot and academic when the issue presented is no longer live or the parties lack a legally cognizable interest in the outcome. In essence, there is no actual controversy left to resolve.
    How did this case differ from Career Philippines Ship Management, Inc. v. Madjus? In Career Philippines, the satisfaction of the judgment was considered an amicable settlement, implying a voluntary agreement to end the dispute. In this case, the payment was compelled by a writ of execution and made without prejudice, preserving the right to appeal.
    What is a petition for certiorari? A petition for certiorari is a request for a higher court to review the decision of a lower court or tribunal. It is typically used to address errors of jurisdiction or grave abuse of discretion.
    What was the significance of the phrase “without prejudice” in this case? The phrase “without prejudice” indicated that the employer’s payment of the judgment award did not constitute a waiver of their right to appeal the decision. It preserved their ability to challenge the ruling in a higher court.
    What did the Supreme Court order in this case? The Supreme Court granted the petition, reversed the CA’s decision, and remanded the case to the CA for a decision on the merits. This means the CA must now consider the employer’s appeal on its substantive arguments.
    What is the practical implication of this ruling for employers? Employers can comply with writs of execution and satisfy judgment awards without automatically forfeiting their right to appeal. This provides a safeguard against being penalized for complying with legal obligations while still pursuing legal recourse.

    In conclusion, the Supreme Court’s decision in this case provides valuable guidance on the interplay between the satisfaction of judgment awards and the right to appeal in labor disputes. By clarifying that compliance with a writ of execution does not automatically render a case moot, the Court has ensured a more balanced and equitable resolution of these types of disputes. This ruling underscores the importance of clearly defining the terms of any settlement or payment and safeguarding the right to judicial review.

    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: SEACREST MARITIME MANAGEMENT, INC. vs. MAURICIO G. PICAR, JR., G.R. No. 209383, March 11, 2015

  • The End of Litigation: Satisfaction of Judgment and Mootness in Philippine Law

    Once a judgment has been fully satisfied, meaning the winning party has received everything they were awarded, the case is considered closed and cannot be reviewed further. This principle ensures finality in legal disputes, preventing endless appeals and re-litigation. In essence, once the debt is paid, the legal battle is over.

    Paid in Full: How a Satisfied Judgment Ends the Legal Show

    In Joselito Ma. P. Jacinto v. Edgardo Gumaru, Jr., the Supreme Court addressed whether a case could proceed when the judgment had already been satisfied. The petitioner, Joselito Ma. P. Jacinto, sought to overturn a Court of Appeals (CA) decision regarding a labor dispute. However, during the pendency of the appeal, the judgment in favor of the respondent, Edgardo Gumaru, Jr., was fully satisfied. The Supreme Court then had to consider whether this development rendered the case moot, meaning there was no longer a live issue for the court to resolve.

    The factual background involves a labor case where the Labor Arbiter ruled in favor of Gumaru, awarding him separation pay, unpaid wages, damages, and attorney’s fees. Jacinto and F. Jacinto Group, Inc. appealed to the National Labor Relations Commission (NLRC), but the appeal was not perfected due to a failure to post the required bond. As a result, the Labor Arbiter’s decision became final and executory. Jacinto then attempted to challenge the execution of the judgment, arguing that the writ of execution had already expired. However, this was denied by the Labor Arbiter, leading to further appeals.

    The case eventually reached the CA, which dismissed Jacinto’s petition for certiorari due to an improper verification and certification against forum shopping. Jacinto’s counsel, rather than Jacinto himself, had signed these documents. The CA held that this violated the rules requiring the party, not their counsel, to execute these certifications. Jacinto then filed a Motion for Reconsideration, arguing substantial compliance and explaining that he was out of the country and physically unable to sign. This motion was denied, prompting Jacinto to elevate the case to the Supreme Court.

    Before the Supreme Court, Jacinto argued that his counsel was authorized to sign the verification and certification on his behalf, citing his absence and physical inability to sign personally. He also contended that the NLRC committed grave abuse of discretion in ordering further execution proceedings because he claimed that the original Labor Arbiter’s decision had not yet attained finality. However, during the proceedings before the Supreme Court, Gumaru manifested that the judgment award had been fully satisfied. Jacinto did not dispute this claim.

    The Supreme Court then turned to the central question of mootness. The Court acknowledged that, under certain circumstances, a counsel could sign the verification and certification against forum shopping on behalf of a party. The Court referred to Altres v. Empleo, which outlined the rules regarding non-compliance with verification and certification requirements. Specifically, the Court noted that a party-pleader could designate their counsel to sign on their behalf through a Special Power of Attorney if they were unable to sign for reasonable or justifiable reasons.

    Despite acknowledging this procedural point in favor of Jacinto, the Supreme Court ultimately held that the case had become moot and academic. The Court stated that “it is axiomatic that after a judgment has been fully satisfied, the case is deemed terminated once and for all.” The Court further quoted from Spouses Malolos v. Dy, emphasizing that “when a judgment has been satisfied, it passes beyond review, satisfaction being the last act and the end of the proceedings.” This principle is rooted in the idea that once the winning party has received the full benefit of the judgment, there is no longer any actual controversy to be resolved.

    The Court emphasized that satisfaction of the judgment produces a permanent and irrevocable discharge of the obligation. A judgment debtor who voluntarily complies with the judgment is estopped from appealing it. Therefore, since the judgment in favor of Gumaru had been fully satisfied, the Supreme Court found that there were no more proceedings to consider, as the case had effectively ended. Consequently, the Court denied Jacinto’s petition for being moot and academic, underscoring the principle that a satisfied judgment cannot be further reviewed.

    FAQs

    What is the main principle established in this case? The main principle is that once a judgment has been fully satisfied, the case becomes moot and cannot be further reviewed by the courts. This ensures finality in legal disputes.
    What was the procedural issue regarding verification and certification? The procedural issue was whether Jacinto’s counsel could sign the verification and certification against forum shopping on his behalf. The Court acknowledged that this was permissible under certain circumstances, such as when the party is unable to sign due to absence or physical inability.
    What is a “moot and academic” case? A “moot and academic” case is one where the issues presented are no longer live or present an actual controversy. This often occurs when events transpire that resolve the dispute before the court can render a decision.
    What is the effect of satisfying a judgment? Satisfying a judgment means that the winning party has received everything they were awarded in the court’s decision. Once a judgment is satisfied, it produces a permanent and irrevocable discharge of the obligation.
    Why was the petition denied in this case? The petition was denied because the judgment in favor of the respondent, Gumaru, had already been fully satisfied. This rendered the case moot and academic, precluding further review by the Supreme Court.
    What is a writ of certiorari? A writ of certiorari is a discretionary writ issued by a higher court to review the decision of a lower court. It is not demandable as a matter of right and is granted only in certain circumstances.
    What does it mean for a decision to be “final and executory”? A decision is “final and executory” when all avenues for appeal have been exhausted or the time for appeal has lapsed. At this point, the decision can be enforced through a writ of execution.
    What is the significance of Altres v. Empleo in this case? Altres v. Empleo provided the framework for determining whether non-compliance with verification and certification requirements could be excused. It clarified when a counsel could sign on behalf of a party.

    The Jacinto v. Gumaru case reaffirms the fundamental principle that satisfaction of judgment brings finality to legal disputes. While procedural rules are important, the overarching goal of the legal system is to resolve conflicts effectively and efficiently. Once a judgment is fully satisfied, the courts generally will not intervene further, recognizing that the matter has been concluded.

    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: Jacinto v. Gumaru, G.R. No. 191906, June 02, 2014

  • Enforcing Final Judgments: Proving Payment and Avoiding Falsification Charges

    The Importance of Proof of Payment in Satisfying a Judgment

    DELSAN TRANSPORT LINES, INC., PETITIONER, VS. COURT OF APPEALS AND AMERICAN HOME ASSURANCE COMPANY, RESPONDENTS. G.R. No. 112288, February 20, 1997

    Imagine winning a court case after years of litigation, only to find the losing party claiming they already paid but offering no credible proof. This scenario highlights the critical importance of proper documentation and transparency in satisfying court judgments. The case of Delsan Transport Lines, Inc. vs. Court of Appeals underscores the legal pitfalls of failing to provide adequate evidence of payment and the potential consequences, including accusations of falsification.

    In this case, Delsan Transport Lines, Inc. (Delsan) was ordered to pay American Home Assurance Company (American Home) a substantial sum. Delsan claimed to have satisfied the judgment but failed to provide sufficient proof, leading to a dispute over the execution of the judgment. This ultimately led to further legal complications and even the threat of criminal prosecution.

    Understanding Execution of Judgments

    The execution of a judgment is the process by which a court enforces its decision. Once a judgment becomes final and executory, the prevailing party has the right to seek its enforcement. This often involves a writ of execution, which directs a sheriff to seize and sell the losing party’s assets to satisfy the judgment.

    However, the losing party can prevent execution by demonstrating that the judgment has already been satisfied. This requires clear and convincing evidence, such as official receipts, canceled checks, or other documentation showing proof of payment. The burden of proving satisfaction rests on the party claiming to have made the payment.

    Rule 39, Section 1 of the Rules of Court governs execution of judgments. It states that execution shall issue as a matter of right, on motion, upon a judgment or order that disposes of the action or proceeding.

    For example, suppose a small business owner is sued for breach of contract and loses the case. The court orders them to pay damages. If the business owner pays the full amount and obtains a signed receipt from the plaintiff, they can present this receipt to the court to prevent the execution of the judgment. Without such proof, the plaintiff can proceed with seizing the business’s assets to recover the debt.

    Delsan Transport Lines vs. Court of Appeals: A Case Breakdown

    The case unfolded as follows:

    1. Initial Lawsuit: American Home filed a case against Delsan for a sum of money in 1980.
    2. RTC Decision: In 1991, the Regional Trial Court (RTC) ordered Delsan to pay American Home P1,180,115.77 plus interest, attorney’s fees, and costs.
    3. Notice of Appeal: Delsan filed a notice of appeal through Atty. Noel L. Montilla.
    4. Motion to Dismiss Appeal: Delsan later moved to dismiss the appeal, claiming the judgment had been satisfied, presenting a “Satisfaction of Judgment” document.
    5. Dispute Arises: American Home, through new counsel, denied receiving any payment and sought execution of the judgment.
    6. RTC Orders Execution: The RTC granted American Home’s motion, finding Delsan failed to prove payment.
    7. CA Petition: Delsan filed a petition for certiorari with the Court of Appeals (CA), arguing that the “Satisfaction of Judgment” was valid.
    8. CA Dismisses Petition: The CA dismissed Delsan’s petition, questioned the authenticity of the “Satisfaction of Judgment,” and referred the matter for possible criminal prosecution.

    The Court of Appeals emphasized the lack of concrete evidence from Delsan:

    “There is something terribly wrong with the instant petition as petitioner claims having fully satisfied the judgment of the respondent court in the enormous amount of more than P1.1 Million, and yet could not produce a small receipt, or even the check evidencing said payment to private respondent.”

    Furthermore, the appellate court highlighted the inconsistency in Delsan’s actions:

    “Moreover, if it were true that said satisfaction of judgment was made by petitioner and counsel on August 26, 1991, said petitioner did not have to file their notice of appeal on September 9, 1991, or fourteen days later from the signing of the said document on satisfaction of judgment.”

    The Supreme Court ultimately affirmed the Court of Appeals’ decision, highlighting Delsan’s failure to provide sufficient evidence of payment and referring the involved attorneys for investigation due to the questionable “Satisfaction of Judgment” document.

    Practical Implications and Key Lessons

    This case provides several crucial lessons for businesses and individuals involved in legal disputes:

    • Document Everything: Always obtain and retain official receipts or other verifiable proof of payment for any financial transactions related to a court judgment.
    • Transparency is Key: Ensure all actions taken in relation to a legal case are transparent and properly documented.
    • Verify Legal Documents: Double-check the accuracy and validity of all legal documents before submitting them to the court.
    • Act Promptly: Address any discrepancies or issues related to payment or satisfaction of judgment immediately.

    Failing to adhere to these principles can lead to severe consequences, including the execution of a judgment despite alleged payment, accusations of falsification, and potential disciplinary actions against legal counsel.

    Frequently Asked Questions

    Here are some frequently asked questions about satisfying court judgments:

    Q: What constitutes sufficient proof of payment?

    A: Sufficient proof includes official receipts, canceled checks, bank statements, or any other verifiable documentation that clearly demonstrates payment to the prevailing party.

    Q: What happens if I lose the receipt for a payment I made?

    A: Contact the recipient and request a duplicate receipt or a certification of payment. Bank records or other secondary evidence may also be helpful.

    Q: Can I pay the judgment directly to the lawyer of the winning party?

    A: Yes, but it is crucial to obtain a written acknowledgment from the lawyer confirming receipt of the payment on behalf of their client.

    Q: What should I do if the winning party refuses to acknowledge my payment?

    A: File a motion with the court to compel the winning party to acknowledge the payment. Provide all available evidence of payment to support your motion.

    Q: How long do I have to satisfy a judgment?

    A: A judgment can be executed within five (5) years from the date of its entry. After five years but before it is barred by the statute of limitations which is ten (10) years, a judgment can only be executed by virtue of a court action.

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