G.R. No. 83720 - Enriquez vs. Court of Appeals

Petitioner Felicitas Enriquez and the private respondents (spouses Reynaldo Santos and Natividad Santos) were long-time occupants/tenants of adjacent lots along Laon Laan St., Caloocan City.
The lots were part of a large tract owned by spouses Atty. Justo de Dios and Basilia Manotoc.
In 1976, the private respondents purchased a 200-square meter portion of the tract, which was evidenced by Transfer Certificate of Title No. C-2892 issued in their favor.
It was later discovered (in 1978) that petitioner’s house was constructed within the said 200-square meter lot.

Upon the discovery of the overlap, petitioner was informed that her monthly rental should be paid to the private respondents.
Petitioner started paying rental to the respondents, but a dispute soon arose over the acceptance of these payments.
On 11 February 1981, petitioner filed a case for consignation with the city court of Caloocan City after respondents allegedly refused to accept her rental payments, although the case was later dismissed when Reynaldo Santos indicated his willingness to accept them.

On 9 September 1982, the private respondents filed an ejectment suit (Civil Case No. 15302) against petitioner for non-payment of lease rentals since October 1981 and claiming the need of the lot for their own use.
On 1 July 1983, the Metropolitan Trial Court of Caloocan City ordered petitioner to vacate and remove her house from the lot covered by TCT No. C-2892.
Petitioner appealed the decision in Civil Case No. 15302 to the Regional Trial Court (Civil Case No. C-10963), which later affirmed the lower court’s ruling.

In January 1983, petitioner filed a complaint for annulment of the deed of sale and damages against the respondents (Civil Case No. 10583), which was dismissed in March 1983 without prejudice to a later filing.
In June 1983, petitioner proceeded with another action for damages (Civil Case No. C-10837) against the same respondents.

On 26 November 1984, the Regional Trial Court of Caloocan City (Branch 126) rendered a judgment in favor of petitioner.
The judgment ordered the respondents to sell the 90-square meter portion of the lot (where petitioner’s house is located) at the price of P100.00 per square meter, as well as to pay moral damages, exemplary damages, attorney’s fees, and other segregated costs.

The respondents filed a petition for certiorari under Rule 65 before the Intermediate Court of Appeals (initially as IAC G.R. SP No. 05318 and later re-docketed as AC-G.R. CV No. 05806), contesting the decision of the Regional Trial Court.
The appellate court initially dismissed the appeal based on the untimely filing of the notice of appeal and motion for reconsideration.
Subsequently, the appellate court reversed its earlier action and reinstated the appeal after attributing the lapse to accident or excusable negligence (resolution dated 15 April 1986).
On 27 August 1987, the Court of Appeals rendered a new decision setting aside the trial court’s decision.
Petitioner filed a motion for reconsideration on 30 September 1987, which was denied by the Court of Appeals on 26 January 1988.
The decision of the Court of Appeals became final and executory on 3 February 1988, as evidenced by the entry of judgment on 15 April 1988.

Petitioner filed the present special civil action of certiorari under Rule 65 on 22 June 1988, challenging the acquiescence to the final and executory decision of the appellate court.
Private respondents argued that because the appellate decision had become final, no further relief could be granted, emphasizing the principle of finality in judgments.
Petitioner contended that Rule 65 was proper since the ordinary appeal remedy was either lost or rendered ineffective by the finality of the decision.

Whether the special civil action of certiorari under Rule 65 is an appropriate remedy when an appellate decision has become final and executory.

Can a Rule 65 petition be used to challenge a decision that has already acquired finality, even if it is alleged to be erroneous?
Does the doctrine of finality preclude a certiorari petition in cases where there is no interval for a regular appeal?

Whether the appellate decision rendered by the Court of Appeals, which set aside the trial court’s order, is immune from further relief due to its finality.

Should a final and executory judgment be disturbed by a subsequent special civil action?
Is petitioner's claim that no speedy and adequate remedy exists in the ordinary course of law justified under the circumstances?

Whether the established doctrine that “a judgment which has become final and executory is the law of the case” applies, thereby barring the present action.