G.R. No. 207950 - People vs. Chavez y Bitancor

A civil case for ejectment and damages was filed on September 14, 2005, in the Metropolitan Trial Court (MeTC), Branch 39, Quezon City (Civil Case No. 35076).
The case involved Efrain Limsui, the buyer and plaintiff, who acquired eight (8) parcels of land formerly owned by Dr. Carmen Lopez, as evidenced by several Transfer Certificates of Title issued in 1957.
The property had been occupied by squatters: initially caretakers (accompanied by their families) were allowed to reside by Lopez, who later permitted their friends to join, eventually leading to the formation of unauthorized occupants.

The squatters in Lot No. 81 organized as "Damayang Magkakapitbahay ng 81 Linaw Street, Inc." while those in the other portions formed "B.I.G.K.I.S. Neighborhood Association."
Owing to the presence of squatters, prospective buyers were discouraged, which led Limsui to acquire the property at a lower price while assuming the risks associated with the occupants.

In February 2005, representatives of Limsui initiated discussions with leaders of the defendant associations and local barangay officials to coax the occupants into vacating, in exchange for financial and other material assistance.
A Compromise Agreement was reached and presented to the court on September 26, 2005, wherein:

The defendants agreed to voluntarily vacate and remove all structures.
The defendants acknowledged the ownership and the prior arrangement under which Lopez had tolerated their occupation.

The trial court rendered a Decision on November 2, 2005, based on the submitted compromise agreement.

On October 21, 2005, Katipunan ng Tinig sa Adhikain, Inc. (KATIHAN) and Pagsasama sa Iisang Adhikain (PIA) submitted a Verified Manifestation and Motion with the court.
They claimed to be residents of the property who were not parties to Civil Case No. 35076 and asserted that they were at risk of eviction without due process.
They argued that the execution of the decision should not affect them and raised concerns over the alleged destruction of their houses by armed men on October 14, 2005.

On November 23, 2005, the MeTC issued an Order for a writ of execution based on the Decision of November 2, 2005.
Subsequently, on November 30, 2005, a Writ of Execution was issued which commanded the defendants to vacate the premises and restore possession to the plaintiff.
On the same day, Sheriff Antolin Ortega Cuizon issued a Notice to Vacate, followed by a Final Notice of Demolition on June 28, 2006, setting a deadline (July 3, 2006) for vacating and demolition of the structures.

On July 4, 2006, following a reported verbal agreement between the plaintiff’s counsel and the occupants, Sheriff Cuizon proceeded with the demolition after verifying that the occupants had vacated and that demolition of structures was needed.
KATIHAN subsequently filed an administrative complaint against Judge Luis Zenon O. Maceren and Sheriff Cuizon, asserting:

The eviction/execution of the writ was carried out in violation of due process.
The demolition was implemented without a proper court order, as neither a special order of demolition nor a proper hearing had been conducted.

Judge Maceren acknowledged the Verified Manifestation and Motion filed by PIA and KATIHAN but maintained that as non-parties, these motions did not warrant intervention in the substantive ejectment case.
Sheriff Cuizon, while executing his duties under the writ, stated that his issuance of the Notice to Vacate and Final Notice of Demolition was based on the court’s Decision and Writ of Execution, though he later was challenged for acting without proper authority.

Violating the due process rights of the occupants who were not parties to Civil Case No. 35076.
Implementing the demolition of structures without securing a special order from the court, as required by the Rules of Court.

Whether the actions attributable to both the judge and the sheriff, such as:

The judge’s acknowledgment (or alleged participation) in the domino effect of demolition.
The sheriff’s issuance of the Final Notice of Demolition and failure to comply with mandatory procedural requirements, constitute grounds for administrative sanctions.

Whether the non-intervention by the trial court regarding the Verified Manifestation and Motion, due to the movants’ non-party status, affected the due process rights of those indirectly involved.