G.R. No. 120132 - Galay vs. Court of Appeals

The legislature enacted Republic Act No. 7279, known as the "Urban Development and Housing Act of 1992", to improve living conditions in urban poor communities and address the problem of squatting.
The statute seeks to streamline the process of eviction, demolition, and resettlement by imposing mandatory procedures to protect those affected.

Private respondent Virginia Wong, represented by her Administrator and Attorney Atty. Reynaldo B. Hernandez, filed an ejectment suit (Civil Case No. 38-5830) against petitioners.
The petitioners were alleged to be illegally occupying a 405-square-meter lot in Quezon City, which is covered by Transfer Certificate of Title No. 51589.
Although petitioners did not claim ownership, they disputed the respondent’s title and asserted possession of the property since 1972 based on the alleged tolerance and permission of the real owner, Dr. Alejo Lopez.

On August 3, 1992, the Metropolitan Trial Court of Quezon City rendered judgment ordering the ejectment of petitioners.
The decision was affirmed in all respects by an appeal to the Regional Trial Court of Quezon City, Branch 83.
Petitioners’ subsequent petition for review before the Court of Appeals was dismissed for failing to state material dates and lacking certified copies, thereby rendering the judgment final.

The private respondent obtained an Alias Writ of Execution on March 25, 1994, based on the final and executory judgment.
Petitioners sought relief by filing a complaint for Injunction with Preliminary Injunction and Temporary Restraining Order before the RTC of Quezon City, Branch 216, arguing that the execution must await compliance with Section 28(c) of RA 7279.
The RTC denied the restraining order on April 5, 1994, determining that the action in question was based on a lawful court order.
Petitioners further escalated the matter to the Court of Appeals via a petition for certiorari with a prayer for preliminary injunction, which granted the injunction on April 28, 1994, enjoining the ejection pending further order.

On July 18, 1994, counsel for the private respondent filed a Motion to Lift and/or Dissolve the Preliminary Injunction, noting compliance with RA 7279 by providing the mandatory 45-day notice, thus justifying the execution of the judgment.
Petitioners countered that RA 7279 not only requires a 45-day notice but also mandates the relocation of occupants with financial assistance before eviction can occur.
On September 20, 1994, the Court of Appeals issued a decision ordering:

The relocation of petitioners by the People’s Bureau (and cooperating local agencies) to be completed by October 30, 1994.
In cases of delay beyond October 30, 1994, a daily allowance of P145.00 (for up to 60 days) would be granted until relocation was effected.
Upon the deadline, if relocation was incomplete, the private respondent could proceed with ejectment.

Petitioners later argued that the CA decision was based on an unauthorized compromise agreement to which they neither consented nor had knowledge.
Portions of the decision were interpreted by petitioners as evidencing a bilateral agreement with the People’s Bureau representative regarding the terms of relocation and daily allowance.
Petitioners asserted that their former counsel acted without proper authority in finalizing any such agreement and subsequently withdrew his appearance.

Petitioners contended that there should be no eviction and demolition without actual relocation and comprehensive financial assistance.
They questioned whether they could be considered underprivileged and homeless, thereby meriting additional protection.
Moreover, petitioners claimed that the duty to relocate should be shared with the private respondent.

The Court of Appeals, in its resolution dated May 4, 1995, denied the Motion to Set Aside Decision.
The CA reiterated that its decision was rendered on the merits pursuant to the provisions of RA 7279 rather than on any compromise agreement.

Whether an eviction and demolition can lawfully be carried out without actual relocation and the complete implementation of financial assistance as mandated by Section 28(c) of RA 7279.
Whether the mere expiration of the 45-day notice period suffices to trigger execution of the judgment.

Whether petitioners can rightly be considered as underprivileged and homeless, thereby justifying additional legal protection and enhanced relief.
Whether their socio-economic status should influence the application of the eviction and relocation provisions of RA 7279.

Determining whether the statutory duty to relocate belongs exclusively to the local government unit and the National Housing Authority, or can be partially shouldered by the private respondent.
The proper interpretation of RA 7279 regarding the allocation of responsibilities in the relocation process.

Whether the Court of Appeals’ decision was improperly based on a compromise agreement that petitioners neither consented to nor were aware of.
The implications of such an alleged compromise for the validity of the CA decision and subsequent execution proceedings.