Case Digest (G.R. No. L-30871)
Facts:
The case involves two consolidated petitions: G.R. No. L-30871 filed by Aurora P. de Leon and G.R. No. L-31603 filed by Eusebio Bernabe. The events leading to the case began with a judgment rendered in favor of Enrique de Leon against Eusebio Bernabe for damages amounting to P35,000.00 in Civil Case No. C-189, presided over by Judge Fernando A. Cruz of Branch XII of the Court of First Instance of Rizal, Caloocan City. The judgment became final and executory, prompting the issuance of a writ of execution. On November 8, 1966, the city sheriff levied on two parcels of land owned by Bernabe, each measuring 682.5 square meters, which were registered under T.C.T. Nos. 94985 and 94986. These properties were sold at an execution sale on February 14, 1967, to Aurora P. de Leon, who was the highest bidder at P30,194.00, despite the properties being subject to a mortgage lien of P120,000.00. A certificate of sale was executed in Aurora's favor and registered on February 21, 1967.
... Case Digest (G.R. No. L-30871)
Facts:
Background of the Dispute: The case involves two consolidated special civil actions (G.R. No. L-30871 and G.R. No. L-31603) related to the same properties and a jurisdictional conflict between two branches of the Court of First Instance of Rizal in Caloocan City.
Civil Case No. C-189:
- Enrique de Leon obtained a final and executory judgment for P35,000.00 in damages against Eusebio Bernabe.
- A writ of execution was issued, and on November 8, 1966, the city sheriff levied two parcels of land registered under Bernabe’s name (T.C.T. Nos. 94985 and 94986).
- The properties were sold at a public auction on February 14, 1967, to Aurora P. de Leon (Enrique’s sister) for P30,194.00. The properties were subject to an existing mortgage lien of P120,000.00.
- The sheriff issued a certificate of sale in Aurora’s favor, registered on February 21, 1967.
Civil Case No. C-1217:
- On February 7, 1968, Bernabe filed a separate action (Civil Case No. C-1217) against Enrique, Aurora, and the sheriff, seeking to annul the execution sale as "anomalous and irregular" and requesting a new auction sale.
- Instead of assigning the case to Judge Cruz (who presided over Branch XII, where the writ of execution was issued), it was assigned to Judge Salvador of Branch XIV.
- On February 19, 1968, Judge Salvador issued a preliminary injunction, enjoining the sheriff from proceeding with the execution sale or issuing a deed of sale to Aurora upon the expiration of the redemption period.
- Aurora moved to dissolve the injunction and dismiss the case, arguing laches and lack of jurisdiction, but Judge Salvador denied the motion.
Redemption and Further Proceedings:
- On May 20, 1969, Judge Salvador granted Bernabe’s ex-parte motions and ordered the sheriff to allow Bernabe to redeem the properties, despite the redemption period having expired on February 21, 1968.
- On May 21, 1969, Bernabe deposited P33,817.28 as the redemption price, and the sheriff issued a certificate of redemption, which was registered on May 22, 1969.
- Aurora filed a motion to set aside the redemption order, but Judge Salvador denied it on June 23, 1969, asserting jurisdiction over the case.
- Aurora filed a petition for certiorari, seeking to annul Judge Salvador’s orders and the sheriff’s actions.
Case L-31603:
- In the first case (Civil Case No. C-189), Aurora filed a motion for consolidation of title, which Judge Cruz granted on September 5, 1969, ordering Bernabe to surrender the titles for transfer to Aurora.
- Bernabe filed a petition for certiorari (Case L-31603) challenging Judge Cruz’s orders, arguing lack of jurisdiction due to the pending action in Judge Salvador’s court.
Issue:
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Ruling:
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Ratio:
- Jurisdiction Over Execution Proceedings: The court that issued the writ of execution (Judge Cruz’s Branch XII) retains exclusive jurisdiction over the execution proceedings and all incidents thereof, including the validity of the execution sale. No co-ordinate court (Judge Salvador’s Branch XIV) can interfere with these proceedings.
- Improper Use of Injunction: A court cannot interfere by injunction with the judgments or decrees of another court of concurrent or co-ordinate jurisdiction. Bernabe should have sought relief through proper motions in Judge Cruz’s court, not by filing a separate action in Judge Salvador’s court.
- Redemption Period: Judge Salvador’s order allowing redemption after the expiration of the one-year period was void. The properties were in custodia legis of Judge Cruz’s court, and no other court had jurisdiction to alter the redemption terms.
- Adequacy of Price: The alleged gross inadequacy of the auction price does not justify annulment of the sale, especially when the law provides a right of redemption. The lower price could have facilitated redemption, and Bernabe’s failure to redeem or sell the properties was his own fault.