Title
Agdao Landless Residents Association, Inc. vs. Eugenio
Case
G.R. No. 224052
Decision Date
Dec 6, 2021
ALRAI, as landowner, sued Eugenio, et al. for unlawful detainer. Courts ruled for ALRAI, but respondents challenged execution. SC reinstated demolition, upholding finality of judgment and non-appealability of execution orders.
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Case Digest (G.R. No. 224052)

Facts:

  1. Ownership and Occupation

    • Agdao Landless Residents Association, Inc. (ALRAI) is the registered owner of 15 parcels of land in Bo. Obrero, Davao City, evidenced by titles.
    • Respondents Jimmy Eugenio, Henry Eugenio, Lovell Eugenio, Tomas Perales, and Elena Corgio (Eugenio, et al.) occupied the properties despite not being members of ALRAI.
    • ALRAI sent demands to vacate, but the respondents refused, prompting ALRAI to file an unlawful detainer case.
  2. MTCC Ruling

    • The Municipal Trial Court in Cities (MTCC) ruled in favor of ALRAI, ordering the respondents to vacate the properties, pay monthly rentals, and reimburse litigation expenses.
    • The MTCC found ALRAI’s proof of ownership sufficient.
  3. RTC Branch 11 Ruling

    • Eugenio, et al. appealed but failed to timely file an Appeal Memorandum. The RTC initially dismissed their appeal but later reinstated it.
    • The RTC affirmed the MTCC’s decision, holding that ALRAI had a better right to possess the properties and that membership in ALRAI is not inheritable.
  4. Execution and Survey

    • During execution, Eugenio, et al. filed a motion to clarify the areas to be vacated, leading to a relocation survey by court-appointed commissioners.
    • The majority report confirmed that the respondents’ structures were within ALRAI’s titled property.
    • The MTCC approved the majority report and denied the respondents’ motion for restitution.
  5. RTC Branch 10 Ruling

    • Eugenio, et al. filed a petition for certiorari with the RTC, which ruled in their favor, nullifying the MTCC’s denial of their Notice of Appeal and the Special Writ of Demolition.
    • The RTC held that the MTCC’s order clarifying the areas to be vacated was not an order of execution and could be appealed.
  6. CA Ruling

    • The Court of Appeals (CA) affirmed the RTC’s decision, agreeing that exceptions to the general rule on the non-appealability of execution orders applied.

Issue:

  1. Whether the MTCC Order approving the survey report during execution is appealable.
  2. Whether the CA erred in affirming the RTC’s ruling that the MTCC’s denial of the Notice of Appeal constituted grave abuse of discretion.
  3. Whether the principle of immutability of judgment applies to the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled in favor of ALRAI, reinstating the MTCC’s Order and Special Writ of Demolition. The Court emphasized the immutability of final judgments and the non-appealability of execution orders, except in exceptional circumstances not present in this case.


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