Facts:

This case is entitled Balintawak Construction Supply Corporation vs. Hon. Manuel E. Valenzuela and G.M. Wood Export Industries, Inc., with the decision issued by the Supreme Court's First Division on August 30, 1983. The petitioner, Balintawak Construction Supply Corporation (hereafter referred to as "BALINTAWAK"), initiated the case against the respondent Judge of the then Court of First Instance of Rizal, Branch XXIX, Pasay City, Hon. Manuel E. Valenzuela, and the private respondent, G.M. Wood Export Industries, Inc. (referred to as "GM WOOD"). The dispute arose from two separate cases involving GM WOOD as the defendant.

In Civil Case No. 13446 filed in the Caloocan City Court, BALINTAWAK sought to eject GM WOOD from a leased property due to non-payment of rent. GM WOOD was declared in default after failing to answer the complaint. Consequently, on December 3, 1979, a default judgment was issued ordering GM WOOD to vacate the premises and pay BALINTAWA

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Facts:

Background of the Ejectment Case (CC No. 13446 before the Caloocan City Court)

• Petitioner Balintawak Construction Supply Corporation (BALINTAWAK), as lessor, filed a complaint for ejectment against G.M. Wood Export Industries, Inc. (GM WOOD), the lessee, for non-payment of rentals.
• GM WOOD was declared in default for failure to answer after proper service, leading to an ex parte presentation of evidence by petitioner.
• Judgment was rendered on December 3, 1979, wherein GM WOOD was ordered:
• To immediately vacate the leased premises located at 148 8th Street, between 10th and 11th Avenue, Caloocan City, Metro Manila, and surrender possession to the petitioner.
• To pay rental arrearages totaling P109,877.60 covering the period from April to October 1979, plus continuing monthly rental payments until complete vacation of the premises, along with interest and attorney’s fees.
• To bear the costs of the suit.
• GM WOOD’s attempt to enjoin the issuance and enforcement of the original Writ of Execution by filing a certiorari petition in the Caloocan City Court was dismissed.
• On certiorari elevated to the Court of Appeals, the earlier case (G.R. No. L-54410) involving GM WOOD challenging the default judgment was similarly denied.
• Petitioner subsequently obtained a third Alias Writ of Execution on April 15, 1981, which was then affected by subsequent court orders.

Background of the Attachment Case (CC No. 7928-P before the Court of First Instance of Rizal, Pasay City)

• In a separate action, Traders Royal Bank filed a complaint against GM WOOD and its President-General Manager for recovery of unpaid export advances totaling P3,540,197.34.
• On March 7, 1980, respondent Judge of the Court of First Instance (CFI) of Rizal, Branch XXIX in Pasay City, issued a Writ of Attachment on the machineries, assorted lumber, and office equipment of GM WOOD located in Caloocan City, which were situated in premises leased from BALINTAWAK.
• On April 29, 1980, the attachment was partially lifted upon an agreement by the parties to allow GM WOOD to continue its operations.
• On April 28, 1981, GM WOOD filed a manifestation, contending that the Deputy Sheriff of the Caloocan City Court was about to disturb the properties under attachment pursuant to an ejectment order.
• In response, on April 29, 1981, respondent Judge issued an Order enjoining the deputy sheriff and his auxiliaries from disturbing or interfering with the properties attached.
• Petitioner Balintawak, by way of special appearance, filed a Motion for Reconsideration arguing:
• Lack of jurisdiction by the respondent Judge to issue an injunction-like order affecting the ejectment proceedings.
• That the order should not have been enforced outside of Pasay City given that petitioner was not a party in the CFI case.
• Respondent Judge subsequently denied the Motion for Reconsideration in an Order dated June 5, 1981.
• This denial prompted the filing of the present Petition for Certiorari and Prohibition by petitioner, challenging the Orders of April 29, 1981 and June 5, 1981.

Collateral and Procedural Developments

• On August 5, 1981, a Temporary Restraining Order (TRO) was issued enjoining the enforcement of the challenged Order.
• GM WOOD cited its difficulties and unexpected circumstances in trying to settle its rental obligations, arguing for equity and a chance for rehabilitation.
• Petitioner emphasized its urgent need for enforcing the judgment in view of accrued overdue rentals amounting to P500,000.00 (as of February 14, 1983).
• The petitioner also noted that previous certiorari petitions seeking to enjoin execution of the ejectment judgment had been dismissed, reinforcing its entitlement to execute the judgment.

Issue:

Whether the respondent Judge of the Court of First Instance of Rizal, Pasay City, had acted with jurisdiction in issuing an order enjoining the enforcement of a final and executory ejectment judgment rendered by the Caloocan City Court.

• The core issue involves the propriety and extent of the judicial power to enjoin the execution of a final judgment.
• Whether the order, given its effects, constituted a grave abuse of discretion tantamount to acting with lack or excess of jurisdiction.

Whether the issuance of such an injunction-like order improperly interfered with the rights of the prevailing party (BALINTAWAK) who is entitled to the court-ordered execution of judgment.

• Consideration of whether the properties subject to the attachment (machineries, lumber, and equipment) versus the leased premises (which belong to petitioner) affected the court’s decision.
• Whether GM WOOD’s procedural posture in seeking relief was proper, particularly the failure to file a third-party claim to contest the Writ of Execution.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)