G.R. No. 242644 - Engineer Alex C. Paguio, et al. vs. Commission on Audit, Nilda M. Blanco, et al.

Two separate special civil actions were consolidated because they involved the same properties and a common issue regarding the conflict of jurisdiction between two branches of the Court of First Instance of Rizal in Caloocan City.
One action (Case L-30871) involved a judgment for actual, moral, and exemplary damages awarded to Enrique de Leon against Eusebio Bernabe, leading to an execution sale.
The other action (Case L-31603) arose from a separate civil case (Civil Case No. C-1217) filed by judgment debtor Bernabe, challenging the execution sale and seeking its annulment and a new auction sale.

A final and executory judgment was rendered in favor of Enrique de Leon in Civil Case No. C-189, with damages amounting to P35,000.00.
Pursuant to the writ of execution from Judge Fernando A. Cruz of Branch XII, the city sheriff levied upon two parcels of land (each 682.5 square meters) owned by Bernabe, as recorded in T.C.T. Nos. 94985 and 94986.
The execution sale was held on February 14, 1967, wherein the properties were sold to petitioner Aurora P. De Leon, the sister of the judgment creditor, for a total of P30,194.00, notwithstanding an existing mortgage lien of P120,000.00.
The sheriff subsequently executed the certificate of sale in favor of Aurora, and the sale was registered on February 21, 1967.

Events in the Separate Action Challenging the Execution Sale (Civil Case No. C-1217)

On February 7, 1968, Bernabe filed a separate action in Branch XIV (presided by Judge Serafin Salvador) seeking to annul the execution sale due to alleged irregularities and to order a new auction sale.
The case was assigned to Judge Salvador’s branch, notwithstanding that the execution proceedings were already pending in Branch XII under Judge Cruz.
Judge Salvador issued a writ of preliminary injunction on February 19, 1968, enjoining defendants (including the sheriff) from taking further action against the properties already sold at public auction.
Aurora moved to dissolve the injunction and dismiss the second case on grounds of laches and lack of jurisdiction of Judge Salvador's court to interfere with ongoing execution proceedings, but her motion was initially denied.

On May 20, 1969, while the issue of jurisdiction was still pending, Judge Salvador granted ex parte motions filed by Bernabe, directing the sheriff to allow redemption of the properties, despite the redemption period having ostensibly expired.
Bernabe redeemed the properties on May 21, 1969 by depositing P33,817.28 with the sheriff, who then issued a certificate of redemption and registered it on May 22, 1969.
In the meantime, Aurora filed a motion in the first case (before Judge Cruz) on May 30, 1969 for consolidation of title and required issuance of a final deed of sale in her favor.
Judge Cruz subsequently issued an order on September 5, 1969, granting Aurora’s motion over Bernabe’s opposition, confirming her title by ordering Bernabe to surrender his duplicates of title.
Following this, Bernabe filed Case L-31603 seeking certiorari to annul Judge Cruz’s orders and halting the consolidation of title, challenging the jurisdiction over his redemption and the subsequent proceedings.

The decisive issue centered on which branch of the Caloocan City courts (Branch XII under Judge Cruz or Branch XIV under Judge Salvador) had exclusive jurisdiction over the execution sale and related proceedings.
It was critical to determine whether Judge Salvador’s court could interfere with or set aside the execution sale conducted under Judge Cruz’s authority.
The properties, having been levied upon pursuant to Judge Cruz’s writ of execution, were already in the custodial control (custodia legis) of Branch XII, thereby raising issues concerning the propriety of proceedings in a separate branch for redeeming or annulling the sale.

Whether Branch XII (Judge Cruz’s court) retained exclusive jurisdiction over the execution sale and all subsequent proceedings, including issues regarding the redemption of the properties.
Whether Branch XIV (Judge Salvador’s court) improperly attempted to intervene by issuing orders, including granting a writ of preliminary injunction and a redemption order, over proceedings that were under Judge Cruz’s exclusive control.

Whether the redemption order issued by Judge Salvador on May 20, 1969, allowing Bernabe to redeem the properties after the statutory redemption period had expired, was legally tenable.
Whether Bernabe’s actions and subsequent filings, including the motion for dismissal and the alleged redemption within a non-existent remaining period, were sufficient to validate the issuance of such an order by a court lacking jurisdiction over the properties.

Whether Bernabe’s separate action to challenge the execution sale in Branch XIV violated the principle that a judgment debtor must seek relief from the court that issued the judgment and executed the sale.
Whether the interference by Judge Salvador’s court, including granting relief in a summary, unreasoned manner without due process on the issue of the alleged irregularity of the execution sale, was proper.