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O. VENTANILLA ENTERPRISES CORPORATION v. VELASCO

FACTS:

Petitioner leased out two of its properties to Alfredo S. Tan and private respondent Adelina S. Tan (the Tans). Due to the Tans' failure to comply with the terms of the lease, petitioner filed a complaint for cancellation and termination of the contract of lease with the Regional Trial Court (RTC) of Cabanatuan City. The RTC rendered a Decision in favor of the petitioner, ordering the Tans to surrender possession of the properties and pay various amounts as damages, unpaid rentals, and attorney's fees. Both Alfredo S. Tan and Adelina S. Tan appealed from the Decision. However, petitioner filed a motion for execution pending appeal, which was granted. The Tans decided to pay the amounts ordered by the RTC, and the trial court issued orders lifting and canceling the Notice of Levy on Adelina Tan's properties and bank accounts. The appeal filed by Alfredo S. Tan was dismissed by the Court of Appeals (CA), but the appeal filed by Adelina S. Tan proceeded. The CA partially granted the appeal, deleting the awards of exemplary damages and attorney's fees, and reducing the award of liquidated damages. None of the parties filed any motion for reconsideration or appeal from the CA Decision, making it final and executory. Adelina Tan filed a motion for execution in the trial court, seeking a refund of the excess amounts she previously paid. Meanwhile, petitioner filed an omnibus motion with the CA, seeking to recall the entry of judgment and to reopen the appeal. The trial court granted the motion for execution and ordered the refund of certain amounts to the defendants. Petitioner filed a motion for reconsideration, but it was denied. Petitioner then filed a petition for certiorari with the CA to challenge the trial court's orders.

ISSUES:

  1. Whether the Court of Appeals erred in refusing to recall its entry of judgment and denying petitioner's Motion for Reconsideration.

  2. Whether the trial court erred in granting the Motion for Execution and ordering the refund of the excess amounts paid by private respondent.

RULING:

  1. The Court of Appeals did not err in refusing to recall its entry of judgment and denying petitioner's Motion for Reconsideration. The Court found that the petitioner failed to provide any valid ground or basis for the recall of entry of judgment. The settlement between the parties and the death of petitioner's counsel do not suffice to warrant the recall of entry of judgment.

  2. The trial court did not err in granting the Motion for Execution and ordering the refund of the excess amounts paid by private respondent. The Court upheld the trial court's decision, as it was in accordance with the CA Decision reducing the awards of exemplary damages, attorney's fees, and liquidated damages. Therefore, the refund of the excess amounts paid by private respondent is justified.

PRINCIPLES:

  • Once a decision becomes final and executory, it should not be disturbed, except for very strong and cogent reasons, as to do so would undermine the stability of the judicial process and the orderly administration of justice.

  • Settlement between parties and the death of counsel do not automatically warrant the recall of entry of judgment, as there must be valid grounds or bases for such recall.

  • The trial court's decision regarding the execution and refund of excess amounts paid should be in accordance with the final judgment rendered by the appellate court.