G.R. No. 75206 - Galgala vs. Benguet Consolidated, Inc.

On May 19, 1977, the late spouses Tomas and Francisca Galgala executed a Memorandum of Agreement with Benguet Consolidated, Inc.

They acknowledged a cash shortage of P772,419.34 allegedly incurred between 1958 and 1976 during the period when Francisca Galgala worked as a medical assistant in the respondent’s laboratory.
To settle the alleged shortage, they undertook to repay the amount by selling three parcels of land.

The spouses executed three deeds of sale on the same day: two for parcels in Baguio City and one for a parcel in Barrio Betag, La Trinidad, Benguet.
Subsequent to the sales, the respondent redeemed the lots from the First Peso Savings Bank and the Philippine National Bank.
The titles were then transferred to Benguet Consolidated, Inc., resulting in the issuance of Transfer Certificates of Title Nos. T-29158 and T-29151 for Baguio City and T-13907 for Benguet.

The spouses Galgala were allowed to remain on the premises initially either to find alternative accommodation or later as lessees.
Due to their failure to pay agreed rentals and eventually to vacate the premises after repeated demands, Benguet Consolidated, Inc. filed an action for unlawful detainer and damages.

Filed on April 11, 1979, the action (Civil Case No. 6766) was adjudicated in the Municipal Trial Court of Baguio, chaired by Judge Braulio D. Yaranon.
On November 26, 1983, the trial court rendered a decision ordering the defendants to vacate the premises, pay monthly compensation at P1,000.00, and cover interest and costs.
The decision became final and executory upon expiration of the period for appeal.

On September 20, 1979, the spouses Galgala initiated Civil Case No. 3656 in the Court of First Instance (now the Regional Trial Court) for the annulment of the memorandum of agreement and deeds of sale.
They alleged vitiation of consent by force, duress, and fear, seeking to have the documents set aside and the properties reconveyed.

On June 5, 1984, petitioners filed a verified petition for a preliminary injunction in Civil Case No. 3656 aimed at stopping the execution of the ejectment judgment.
The Regional Trial Court of Baguio City, presided over by Judge Stella Dadivas-Farrales, denied the petition on January 9, 1986.
Subsequent motions for reconsideration and certiorari before the Intermediate Appellate Court (now Court of Appeals) were likewise denied.

Petitioners contended that execution of the ejectment judgment should await the resolution of the annulment case because the annulment action challenges the validity of the transactions and implicates the title on the same properties.

Benguet Consolidated, Inc. maintained that the ejectment action and the annulment suit are separate actions: one dealing solely with possession (unlawful detainer) and the other with title (annulment).
They argued that the pendency of the annulment case cannot serve as a valid reason to stay the execution of the ejectment judgment, which is aimed at protecting possession.

Whether the pending annulment action, which challenges the validity of the memorandum of agreement and deeds of sale concerning the same properties, can serve as a basis to delay or stay the execution of the final judgment in the unlawfully detainer (ejectment) case.
Whether the separation between the issues of possession (addressed in the ejectment suit) and title (addressed in the annulment suit) justifies the immediate enforcement of the ejectment judgment.
Whether delaying the execution of the ejectment judgment to await the resolution of the standing annulment case is consistent with the purpose and procedural requirements inherent in summary proceedings for forcible entry or detainer.