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MIRANDA v. PABLO R. MIRANDA

FACTS:

The heirs of Numeriano Miranda, Sr. filed a complaint before the Regional Trial Court (RTC) for annulment of titles and specific performance against the heirs of Pedro Miranda and Tranquilino Miranda, as well as the spouses Pablo Miranda and Aida Lorenzo. After trial, the RTC rendered a decision in 1999 upholding the validity of certain titles and ordering Pablo Miranda to indemnify the other heirs of Numeriano Miranda. The decision also declared Rogelio Miranda as not the biological son of Tranquilino Miranda, and proclaimed the heirs of Tranquilino Miranda, including Pablo Miranda, as the lawful heirs of Tranquilino Miranda. The decision became final and executory.

In 2001, a writ of execution was issued but was not implemented until 2005 when respondent filed a motion for break-open and demolition order. The motion was denied, prompting respondent to file a petition for revival of judgment. The RTC granted the petition and revived the 1999 decision. The heirs of Numeriano Miranda filed a notice of appeal, which was denied by the RTC for being filed out of time. They filed a petition for mandamus with the Court of Appeals, but it was denied.

ISSUES:

  1. Whether the appeal was perfected on time.

  2. Whether the late filing of the appeal was justified.

  3. Whether an action for revival of judgment is appealable.

  4. Whether the appeal is meritorious.

  5. Whether the Regional Trial Court has exclusive original jurisdiction over an action for revival of judgment.

  6. Whether the respondent, as one of the judgment creditors, can file the action for revival alone.

  7. Whether subsequent events or laws have rendered the judgment sought to be revived modified or prevented its enforcement.

  8. Whether res judicata or laches has seeped in, with the other judgment creditors not suing for any implementation of the 1999 judgment.

RULING:

  1. The appeal was not perfected on time.

  2. The late filing of the appeal was not justified.

  3. An action for revival of judgment is appealable.

  4. The appeal is not meritorious.

  5. The Regional Trial Court has exclusive original jurisdiction over an action for revival of judgment.

  6. The respondent, as one of the judgment creditors, can file the action for revival alone.

  7. Subsequent events or laws have not rendered the judgment sought to be revived modified or prevented its enforcement.

  8. Res judicata or laches has not seeped in, with the other judgment creditors not suing for any implementation of the 1999 judgment.

PRINCIPLES:

  • An action for revival of judgment cannot modify, alter, or reverse the original judgment, which is already final and executory.

  • The jurisdiction of the Regional Trial Court includes the power to revive a judgment.