Facts:

The case at hand involves Eustaquio Fule as the petitioner and Judge Salvador Abad Santos, along with Enrique Bautista, as the respondents. The sequence of events began on March 8, 1940, when Enrique Bautista filed a petition in the Court of First Instance of Laguna referencing civil case No. 6708. He claimed to be the exclusive and absolute owner of a parcel of land, for which a writ of possession had been issued in his favor. Bautista stated that the provincial sheriff of Laguna had been ordered on three separate occasions, namely on June 29 and August 24, 1939, and again on March 4, 1940, to deliver the property to him. However, Fule, who was in actual possession of the land, refused to vacate. Bautista requested the court to compel Fule to appear and explain his disobedience to the writ and to consider charging him with contempt of court.

In his answer, Fule asserted that he had no knowledge of the civil case and denied any involvement, claiming to have been the absolute own

...

Facts:

Background of the Case

• On March 8, 1940, respondent Enrique Bautista filed a petition with the Court of First Instance of Laguna claiming that he was finally adjudged as the exclusive and absolute owner of a parcel of land in civil case No. 6708.
• A writ of possession was issued in Bautista’s favor on June 29, August 24, 1939, and March 4, 1940, commanding the provincial sheriff of Laguna to deliver the land to him.
• Petitioner Eustaquio Fule was in actual possession of the land and refused to vacate it, prompting the controversy.

Petitioner’s Position and Response

• Eustaquio Fule denied any involvement or participation in the civil case wherein respondent Enrique Bautista was adjudged owner.
• Fule claimed he was unaware of any writ of possession issued against him and maintained that he had been the absolute owner of the land since January 13, 1936.
• Based on his non-party status in the earlier civil case, Fule argued he should not be bound by a judgment or writ issued in that action.

Procedural Posture and Court Order

• On March 20, 1940, the trial court denied Bautista’s prayer to hold Fule in contempt for disobeying the writ of possession.
• Instead, the court ordered Fule to vacate the property “without prejudice to establishing his alleged right of ownership in a proper action.”
• The order of possession became the subject of a petition for certiorari, which led to the present review.

Complex Chain of Title and Related Transactions

• Transaction History
• On or about June 10, 1930, Felipe Suarez sold the property to Gregorio Atienza with a covenant providing him a right of repurchase within ten years.
• On or about December 12, 1930, Gregorio Atienza sold the same property to respondent Enrique Bautista, also with a right of repurchase.
• Litigation Relating to the Property
• On or about June 21, 1932, Gregorio Atienza filed civil case No. 5060 against Enrique Bautista to annul their contract on the ground that it did not express the true agreement and was akin to a usurious loan.
• The action resulted in a judgment, later affirmed by the Court of Appeals, declaring the contract to be an equitable mortgage.
• Subsequently, on April 17, 1935, following Atienza’s failure to pay the mortgage debt, the property was sold at a public auction in favor of Bautista.
• Third-Party Claim and Subsequent Transactions
• Prior to the auction sale, the minors Rubin, Conrado, and Ernesto Atienza (through their mother and guardian ad litem) filed a third-party claim asserting that the property had been donated to them by Gregorio Atienza.
• A separate civil action, docketed as case No. 6708, was commenced by the third-party claimants against Bautista for the recovery of the property.
• Amidst this pending action, on January 13, 1936, Felipe Suarez exercised his right of repurchase from Gregorio Atienza and sold the property to petitioner Eustaquio Fule.
• In civil case No. 6708, a judgment granted the plaintiffs a six-month period to redeem the property from Bautista, which was never acted upon.

Arguments on Successor in Interest

• Respondents contended that petitioner Fule was a successor in interest to the parties (specifically the plaintiffs in civil case No. 6078) by virtue of title acquired subsequent to the commencement of the action.
• They argued that since Felipe Suarez had repurchased the property from Gregorio Atienza, the repurchase right should have transferred to a successor in interest, thereby affecting Fule’s status.
• However, it was demonstrated that Felipe Suarez repurchased from Atienza—not from the minors involved in civil case No. 6078—and thus did not acquire any new title rights beyond those originally held by Atienza.

Issue:

• Whether a writ of possession issued in a civil case can be enforced against a person (petitioner Fule) who was not made a party to that proceeding.
• Whether the judgment rendered in civil case No. 6708, which adjudged Enrique Bautista as owner, can bind a non-party to the proceedings.
• Whether the chain of title—including Felipe Suarez’s repurchase of the property—renders petitioner Fule a successor in interest to the parties involved in civil case No. 6078.
• Whether the order of possession ordering Fule to vacate the land is a valid exercise of jurisdiction given that Fule was not a party to the original proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)