G.R. No. L-26775 - Iriola vs. Felices

Andrew David was a used-car businessman who owned several vehicles—seven serviceable and three unserviceable—as well as parcels of land, including the property with Transfer Certificate of Title (TCT) No. 14793 in Quezon City.
He also held a savings deposit account with the Philippine Savings Bank amounting to P500,000.00 and a life insurance policy worth P1,500,000.00 from the SunLife of Canada Insurance Company.
On May 5, 1994, Andrew David was fatally shot by unidentified assailants while approaching his residence, leaving behind his wife, Teodora David, and his mother, petitioner Rosita David.
Subsequent to his death, issues concerning the settlement of his estate arose when petitioner Rosita David filed a petition for the settlement of the estate, while Teodora opposed the proceedings.

The petitioner and Teodora jointly filed a motion in the estate settlement (Sp. Proc. No. 10436) for joint authority to withdraw P500,000.00 from the PS Bank account, to sell the real property covered by TCT No. 14793, and to collect the life insurance proceeds.
A court order issued on October 20, 1994, granted their motion directing the division of these assets among the heirs of Andrew David.
Teodora later proceeded, as vendor, to execute a deed of conditional sale with the respondent Spouses Rod and Cynthia Navarro for the property at the agreed price of P4,500,000.00, with payment structured in two parts:

A down payment of P1,000,000.00 coupled with conditions regarding vacant possession, mortgage clearance, and transfer of title.
A balance of P3,500,000.00 payable upon the presentation of a valid, transferable, and registerable title.

Petitioner Rosita David did not give her consent to this sale because she had another prospective buyer and contested the sharing of proceeds among the heirs.

After the conditional sale, the Navarro Spouses took possession of the property and utilized part of it for their car sale business, employing several personnel who resided or worked there.
On May 24, 1995, petitioner Rosita David executed an affidavit of adverse claim over the property, asserting her interest as one of Andrew David’s heirs and noting that the estate was still pending settlement in the RTC (Sp. Proc. No. 10436).
The petitioner subsequently filed a complaint for the annulment of the deed of conditional sale in RTC Civil Case No. Q-95-23351. After Teodora and the Navarro Spouses failed to appear at the pre-trial conference, the RTC ruled in favor of the petitioner on August 26, 1997, declaring the deed null and void and imposing attorney’s fees and costs against Teodora.

Teodora and the Navarro Spouses appealed the RTC decision to the Court of Appeals (CA-G.R. CV No. 59872).
In parallel, the petitioner filed a Complaint for Unlawful Detainer before the Metropolitan Trial Court (MTC, Civil Case No. 20064), seeking the eviction of the Navarro Spouses for non-payment of rentals, which was ruled in the petitioner’s favor on November 16, 1998.
The MTC issued a writ of execution against the Navarro Spouses after they failed to post a supersedeas bond. The writ was implemented on February 11, 1999, with possession being turned over to the petitioner by law enforcement assisted by counsel.
Soon thereafter, the Navarro Spouses filed an urgent petition for certiorari in the RTC (Civil Case No. 36725) seeking a temporary restraining order (TRO) to nullify the writ of execution, but that petition was dismissed for procedural non-compliance.
Further, the respondents filed an urgent motion in the Court of Appeals (in CA-G.R. CV No. 59872) for a TRO and later a writ of preliminary injunction to enjoin the execution of the writ, even as the petitioner contended that the deed and execution issues were already effectively settled on the ground of possession having been transferred.

Despite the petitioner’s motion to dismiss the appeal on several grounds—forum shopping and failure to comply with procedural rules—the CA eventually granted a TRO on February 16, 1999, and later a writ of preliminary injunction on March 15, 2000, thereby staying the eviction despite the writ having been enforced.
On March 15, 1999, amid escalating tensions, allegations of robbery, grave coercion, and serious illegal detention were raised by occupants of the property against the petitioner, her counsel, and security personnel, leading to the arrest of the security guards.
The Secretary of Justice later ordered the withdrawal of criminal charges against the security guards.
On June 27, 2000, the RTC reversed the MTC decision in Civil Case No. 20064 by dismissing the petition for unlawful detainer, ruling that the complaint had been prematurely filed now that the deed had been annulled and the estate matters were in appeal.
Petitioner Rosita David ultimately filed a petition for review before the Court of Appeals (CA-G.R. SP No. 64666), contesting the CA resolutions on the grounds of forum shopping and the moot nature of the preliminary injunction being issued after the writ of execution had already been carried out.

The petitioner contended that the CA should have dismissed the appeal of the private respondents on the grounds of forum shopping and failure to comply with Section 1, Rule 50 of the Rules of Court.
The petitioner argued that the temporary restraining order (and subsequent preliminary injunction) was ineffectual since the writ of execution had already been implemented, rendering the injunctive relief moot.
In her view, the CA’s action interfered with the mandatory enforcement of local court orders as provided under the Rules of Court.

Whether the issuance of the temporary restraining order (TRO) and the writ of preliminary injunction by the Court of Appeals was proper given that the writ of execution had already been enforced.
Whether the act sought to be enjoined—namely, the enforcement of the writ of execution—had become a fait accompli.

Whether the respondents engaged in forum shopping by first pursuing injunctive relief in the RTC and then filing a motion in the CA for the same relief.
Whether the respondents’ failure to comply with Section 1, Rule 50 (and relevant provisions in Rule 65) of the Rules of Court was a sufficient basis for dismissal of their appeal.

Whether the issuance of the injunction was rendered moot and academic since the petitioner had already taken possession of the property before the CA granted the TRO and injunction.
Whether the property’s subsequent possession dynamics nullified the need for the injunction.