In Philippine judicial procedure, the only portion of a judgment that may be executed is the dispositive portion (the fallo). Neither the body, nor the reasoning, nor any obiter dictum can be enforced by a writ. Both the sheriff tasked with execution and the losing party against whom execution is directed are legally bound only by the literal, operative text of the dispositive portion.
This principle is settled in doctrine:
1. Execution must conform strictly to the dispositive portion.
A writ of execution “must conform not only to the judgment’s tenor but to its literal terms,” and cannot vary, enlarge, or diminish the judgment. (Republic v. Court of Appeals, G.R. No. 100594)
2. The body of the decision cannot control the fallo.
If there is any inconsistency between the body and the dispositive portion, the latter prevails because it constitutes the final, definitive adjudication. (Heirs of Malate v. Gamboa, G.R. No. 170338)
3. Sheriffs have no authority to interpret or expand the judgment.
A sheriff’s role is ministerial: to execute the judgment as written, not as understood or implied. Any act beyond what the fallo commands is void. (Castillo v. Namuco, G.R. No. 182729)
Thus, until the exact dispositive portion of the Supreme Court’s PhilHealth ruling is released, the following remain impossible:
drafting a proper writ of execution;
determining the precise obligations commanded by the Court;
identifying whether restitution is immediate or requires actions by specific agencies;
enforcing any recovery against officials or contractors.
Media summaries, even official press releases, have no legal force. Only the verbally exact fallo is enforceable.
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Assisted by ChatGPT, December 5, 2025.
