Facts:

The case at hand is a petition for certiorari filed by Elisa Angeles (petitioner) against respondents, which include the Hon. Court of Appeals, Officer-in-Charge Marilou C. Martin, Deputy Sheriff Joselito SP Astorga, Clerk III Marco Boco, and unnamed John Does, arising from a decision dated February 22, 2007. This case originated from a complaint for annulment of a real estate mortgage, foreclosure sale, reconveyance, and damages, docketed as Civil Case No. 69213 in the Regional Trial Court (RTC) of Pasig City under Branch 268. The complaint was filed by spouses Juan and Anatalia Coronel against Angeles and several others.
On April 3, 2005, the trial court ruled in favor of the Coronels, declaring their title valid while ordering the Registry of Deeds in Pasig to cancel the title in issue. Following the trial court's decision, Angeles and her co-defendants filed a Notice of Appeal, while the Coronels sought a motion for execution pending appeal. The RTC initially denied this

...

Facts:

Background of the Underlying Civil Case (Civil Case No. 69213)

• Spouses Juan and Anatalia Coronel filed a complaint seeking annulment of a real estate mortgage, foreclosure sale, reconveyance, and damages against petitioner Elisa Angeles and others.
• On April 3, 2005, the Regional Trial Court of Pasig, Branch 268, rendered a decision:
• Declaring the Transfer Certificate of Title No. PT-113632 null and void.
• Ordering the Registry of Deeds for the City of Pasig to cancel the existing title and issue a new one in the names of spouses Coronel.
• Ordering petitioner to pay P960,000.00 as reimbursement for the redemption of the property.
• No pronouncement on costs.
• Following the decision:
• Petitioner and her co-defendants filed their Notice of Appeal.
• The Coronels filed a motion for execution of the judgment pending appeal, which was initially denied on October 19, 2005.
• On November 15, 2005, the Coronels filed a Motion for Reconsideration.
• Later, on February 1, 2006, the trial court reconsidered the earlier order and granted the execution pending appeal, leading to the issuance of a Writ of Execution Pending Appeal on February 16, 2006.
• The record of the case was transmitted to the Court of Appeals (CA) on February 27, 2006.
• On March 9, 2006, petitioner was evicted from the subject property as a result of the enforcement of the writ.

Petition for Contempt Proceedings

• On March 24, 2006, petitioner Elisa Angeles filed a Petition for Contempt with the Court of Appeals (docketed as CA-G.R. SP No. 93772) against:
• Officer-In-Charge Marilou C. Martin.
• Deputy Sheriff Joselito SP Astorga.
• Clerk III Marco Boco.
• John Does (whose identities were not ascertained).
• Allegations made in the petition:
• Martin allegedly disobeyed the trial court’s November 15, 2005 order to elevate the records of Civil Case No. 69213 to the CA.
• The respondent officers were accused of colluding with the Coronels to secure the issuance of execution pending appeal.
• The petition claimed that the writ of execution pending appeal was issued hastily and irregularly.
• Astorga and Boco were accused of employing trickery in ejecting the petitioner and selectively evicting tenants.
• The petition contended that Astorga, in particular, lacked the authority to enforce the writ since the trial court purportedly lost jurisdiction following the transmission of the records to the CA on February 27, 2006.
• Overall, it was argued that the respondents’ actions amounted to abusive, illegal, and indirect contempt of the appellate court.

Responses and Comments by the Respondents

• Comment by Respondent Martin:
• Asserted that as a mere court employee with limited powers, she could not control the court’s proceedings nor the implementation of court orders.
• Claimed that the non-transmittal of records was inadvertent, a consequence of the trial court’s process of considering various motions.
• Maintained that she had no role in or authority over the enforcement of the writ of execution pending appeal.
• Comments by Respondents Astorga and Boco:
• Denied all allegations, stating that their actions were in strict obedience to the trial court’s directives.
• Explained that any actions they took were solely based on their duty to enforce the orders and writs of the trial court, especially in the absence of a stay order.
• Noted that any disputes or accusations should have been raised with the trial court, not the CA.

Court of Appeals Decision and Subsequent Developments

• On February 22, 2007, the CA issued a decision dismissing the petition for contempt:
• The decision emphasized that the power to determine contempt resides exclusively with the court which issued the order.
• It noted that until an order/resolution is nullified, it is presumed valid and enforceable.
• It underscored that the respondent officers merely implemented ministerial acts required under the trial court’s orders.
• The CA held that proper contempt proceedings should be initiated in the court that issued the order (the trial court) rather than in the appellate court.
• After the dismissal:
• Petitioner filed a Motion for Reconsideration.
• The appellate court denied the Motion for Reconsideration in a June 4, 2007 Resolution.
• The petition eventually reached this Court through a Petition for Certiorari, challenging the CA’s dismissal.

Issue:

Jurisdictional and Discretionary Questions

• Whether the Court of Appeals abused its discretion in dismissing the petition for contempt.
• Whether the respondent public officers acted outside the scope of their authority by allegedly disobeying the trial court’s directives.
• Whether the enforcement of the writ of execution pending appeal, despite the appellate jurisdiction acquired through the perfected appeal, constitutes indirect contempt.
• Whether the proper venue for initiating a contempt proceeding should have been the trial court (the court a quo) rather than the Court of Appeals.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)