Facts:

The case at hand involves Florenda Ariem as the petitioner, with Hon. Walfrido de los Angeles, the People's Homesite & Housing Corporation, and the City Sheriff of Quezon City serving as respondents. This matter reached the Supreme Court of the Philippines and was decided on January 31, 1973. The controversy arose from a judgment rendered on December 4, 1969, in Civil Case No. Q-12775 by the Court of First Instance of Rizal, Branch IV, Quezon City, in favor of the People’s Homesite & Housing Corporation against Nicasio Barles. The court ordered Barles to vacate Lot No. 16, Block 15, Psd-57771 situated in Project 6, Quezon City, which was owned by the Corporation. Following the judgment's finality, a writ of execution was issued on February 16, 1970, directing the City Sheriff to remove any constructions by Barles on the lot.

On May 14, 1970, Ariem filed a petition requesting the lifting of the writ of execution along with a plea for a preliminary injunction to ha

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Facts:

Background of the Case

• The case originates from Civil Case No. Q-12775, wherein the respondent People’s Homesite & Housing Corporation rendered a judgment on December 4, 1969, in its favor against Nicasio Barles, ordering the latter to vacate Lot No. 16, Block 15, Psd-57771, located in Project 6, Quezon City.
• The property in question was registered under Transfer Certificate of Title No. 34802 in the name of People’s Homesite & Housing Corporation.

Issuance and Execution of the Judgment

• After the judgment became final and executory, the presiding judge of the Court of First Instance of Rizal, Branch IV, Quezon City, ordered the issuance of a writ of execution.
• The writ, issued by the Clerk of Court on February 16, 1970, directed the Sheriff of Quezon City to enforce the judgment and cause Nicasio Barles to remove his house and other constructions on the lot.

Intervention by Florenda Ariem

• On May 14, 1970, Florenda Ariem, the petitioner, filed a petition in the same case seeking to lift the writ of execution and requested a writ of preliminary injunction to restrain People’s Homesite & Housing Corporation from executing the judgment.
• In her petition, Ariem claimed that she was the bona fide occupant of the lot, arguing that Nicasio Barles was merely acting as her caretaker during her absence in the provinces.
• The petition was denied by the respondent Judge on June 24, 1970, who allowed the execution of the judgment against Nicasio Barles.

Subsequent Developments and Procedural History

• On July 6, 1970, the Court issued a restraining order to halt the execution of the judgment, including the demolition of Barles’s house and improvements, pending further orders.
• Prior to Florenda Ariem’s petition, Nicasio Barles had also sought relief in a separate petition filed on March 10, 1970, to set aside the default judgment and the eviction order, arguing that he was denied his day in court.
• The petition for relief filed by Barles was denied on May 13, 1970.
• Despite these petitions, the lower court maintained that Nicasio Barles was the real party-in-interest since he had actively participated in the proceedings by filing motions and seeking relief.

Relationships and Allegations

• It was established that Nicasio Barles is Florenda Ariem’s son-in-law.
• The petitioner’s claim was seen as an attempt to delay the eviction and to prevent the execution of the judgment by portraying herself as the bona fide occupant, even though her connection to the property was through her relative, Barles.
• The lower court and later the Court of Appeals maintained that any claim by Ariem as the bona fide occupant was merely an eleventh-hour maneuver aimed at saving Barles from the consequences of the prior judgment.

Issue:

Abuse of Discretion

• Whether the respondent Judge committed grave abuse of discretion in denying Florenda Ariem’s petition to lift the writ of execution and in preventing the execution of the judgment in Civil Case No. Q-12775.

Bona Fide Possession vs. Real Party-in-Interest

• Whether Florenda Ariem’s claim of being the bona fide occupant of Lot No. 16, Block 15 is valid.
• Whether Nicasio Barles, as the actual occupant who partook in court proceedings (by filing a motion to dismiss and later a petition for relief), is the real party-in-interest despite his familial relation to Ariem.

Impact of Family Relationship in Ejectment Cases

• How the familial and relational dynamics (i.e., the relationship between Barles and Ariem) affect the application of execution orders in ejectment cases.
• Whether relatives and privies can be shielded from execution orders if they were not a party to the original proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)