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SIMPLICIA O.

ABRIGO and DEMETRIO ABRIGO, Petitioners,


vs.
JIMMY F. FLORES, EDNA F. FLORES, DANILO FLORES, BELINDA
FLORES, HECTOR. FLORES, MARITES FLORES, HEIRS OF MARIA F.
FLORES, JACINTO FAYLONA, ELISA FAYLONA MAGPANTAY,
MARIETTA FAYLONA CARTACIANO, and HEIRS of TOMASA
BANZUELA VDA. DE FAYLONA, Respondents.
G.R. No. 160786, June 17, 2013

In Simplicia O. Abrigo and Demetrio Abrigo vs. Jimmy F. Flores,


et al., G.R. No. 160786, June 17, 2013,the Supreme Court stated:
“[A] supervening event is an exception to the
execution as a matter of right of a final and
immutable judgment rule, only if it directly
affects the matter already litigated and settled,
or substantially changes the rights or relations
of the parties therein as to render the execution
unjust, impossible or inequitable. A supervening
event consists of facts that transpire after the
judgment became final and executory, or of new
circumstances that develop after the judgment
attained finality, including matters that the
parties were not aware of prior to or during the
trial because such matters were not yet in
existence at that time. In that event, the
interested party may properly seek the stay of
execution or the quashal of the writ of
execution, or he may move the court to modify
or alter the judgment in order to harmonize it
with justice and the supervening event.”
HERNAN C. DALIDA, petitioner,
vs.
SPOUSES ELISEO NAGUIT and ALICIA NAGUIT, respondents.
G.R. No. 170083, June 29, 2007

In Dalida vs. Naguit, the Supreme Court ruled:


“[T]he court may stay immediate execution of
a judgment where supervening events bring
about a material change in the situation of the
parties which makes the execution inequitable,
or where there is no compelling urgency for the
execution because it is not justified by the
prevailing circumstances.”

MERCURY DRUG CORPORATION AND ROLANDO J. DEL


ROSARIO, Petitioners, v. SPOUSES RICHARD Y. HUANG & CARMEN G.
HUANG, AND STEPHEN G. HUANG, Respondents.
G.R. No. 197654, August 30, 2017
LEONEN, J.:

In Mercury Drug Corporation and Rolando J. Del Rosario vs. Sps.


Richard and Carmen Huang, and Stephen Huang the Supreme Court
extensively discussed supervening events as an exception to the doctrine of
immutability of judgments, to wit:
“The happening of a supervening event is
likewise a ground to set aside or amend a final
and executory judgment.

This exception was explained in Natalia


Realty, Inc. v. Court of Appeals, thus:

One of the exceptions to the principle of


immutability of final judgments is the existence
of supervening events. Supervening events
refer to facts which transpire after judgment
has become final and executory or to new
circumstances which developed after the
judgment has acquired finality, including
matters which the parties were not aware of
prior to or during the trial as they were not yet
in existence at that time.
Parties must establish two (2) conditions
in order to properly invoke the exception on
supervening events. First, the fact constituting
the supervening event must have transpired
after the judgment has become final and
executory. It should not have existed prior to
the finality of the judgment. Second, it must be
shown that the supervening event affects or
changes the substance of the judgment and
renders its execution inequitable.”

In Mercury Drug Corp., the Supreme Court also mentioned several


cases where supervening event was applied as an exception to the doctrine of
immutability of judgment as follows:

“In Roman Catholic Archbishop of Caceres v.


Heirs of Manuel Abella, a civil case for quieting
of title was considered as a supervening event
that rendered a previous case for forcible entry
unenforceable through execution. This Court
held that the judgment in the case for quieting
of title is a "new circumstance which developed
after the finality of the judgment in the forcible
entry [case] . . . [which] conclusively resolved
the issue of ownership over the subject land,
and the concomitant right of possession[.]" The
execution of the judgment in the forcible entry
case would, therefore, be unjust and inequitable
to the respondents "who had been conclusively
declared the owners and rightful possessors of
the disputed land."

Bani Rural Bank. Inc. v. De Guzman is another


instance where the exception was applied. The
development of strained relations between the
employer and the employee was considered as
a supervening event that rendered the
execution of the judgment, ordering the
reinstatement of the employee, impossible.”

The Supreme Court, in Mercury Drug Corp. further discussed the


applicability of supervening events, viz:
“[S]everal cases have also been excluded
from the application of the doctrine of
immutability of judgment in the interest of
substantial justice. The exception sometimes
applied when a party's liberty is involved or
when there are special and compelling
circumstances. For instance, judgments of
conviction that have attained finality were
modified to correct an erroneous penalty
previously imposed.

Judgments may also be modified or amended to


supply operational matters that are deemed
necessary to carry out the decision into effect.”