Case Digest (G.R. No. 197142) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mangahas v. Paredes, petitioners Augusto Mangahas and Marilou Verdejo sought to annul the 14 February 2003 Order of the Regional Trial Court (RTC), Branch 124, Caloocan City, which denied their Motion to Suspend Execution in Civil Case No. C-19097. The underlying ejectment suit was filed on 31 January 1997 by private respondent Avelino Banaag before the Metropolitan Trial Court (MeTC), Branch 49, Caloocan City. Banaag claimed title to Lot 4, Block 21, Maligaya Park Subdivision, Caloocan City, by Transfer Certificate of Title No. 196025, and alleged that petitioners built houses thereon without consent. Petitioners opposed, asserting they occupied the lot since 1978 with the consent of the prior owner, PIADECO, under a Certificate of Occupancy. They also invoked a Writ of Preliminary Injunction issued by RTC, Quezon City (Civil Case No. Q-96-29810) on 10 November 1997, enjoining eviction of occupants of the “Tala Estate.” The MeTC denied their motion to suspend proceedings on Case Digest (G.R. No. 197142) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and Preliminary Proceedings
- On 31 January 1997, private respondent Avelino Banaag filed an ejectment suit (MeTC Branch 49, Caloocan City) against petitioners Augusto Mangahas and Marilou Verdejo, alleging he was the registered owner of Lot 4, Block 21 (TCT No. 196025) and that petitioners unlawfully built and occupied houses on the land despite repeated demands to vacate.
- Petitioners denied unlawful possession, claiming they had occupied the lot since 1978 with the knowledge and consent of the prior owner, Pinagkamaligan Indo-Agro Development Corporation (PIADECO), evidenced by a Certificate of Occupancy.
- Motions and MeTC Decision
- Petitioners moved to suspend proceedings, invoking a Writ of Preliminary Injunction issued on 10 November 1997 by RTC Quezon City (enjoining eviction and demolition of Tala Estate occupants). MeTC Caloocan (7 August 1997) denied the motion, ruling the Quezon City injunction lacked extraterritorial effect.
- Parties filed position papers on:
- Validity of Banaag’s Torrens title as basis for ejectment;
- MeTC’s jurisdiction; and
- Claims for damages.
- MeTC Decision (5 October 1999) ruled for Banaag: TCT No. 196025 is indefeasible; petitioners had inferior right. Decree: vacate premises; pay P2,000/month from August 1996 until vacation; reimburse P10,000 attorney’s fees; pay suit costs.
- Appeals and Execution Proceedings
- RTC Caloocan (C-19097) affirmed MeTC Decision (16 November 2000) and denied reconsideration (1 June 2001).
- CA (CA-G.R. SP No. 65076) affirmed RTC (25 April 2002); denied motion for reconsideration (20 November 2002); decision became final and executory (13 December 2002).
- Banaag’s motion for execution pending appeal was granted (12 September 2001); writ of execution issued (27 September 2001); petitioners’ motion to reconsider denied (5 February 2002).
- Petitioners filed Motion to Suspend Execution (17 January 2003); RTC denied it (14 February 2003). Sheriff Erlito Bacho enforced the writ (5 March 2003).
- Petition to the Supreme Court
- Petitioners filed a direct petition for Declaratory Relief, Certiorari, and Prohibition with Provisional Remedy before the SC, seeking to nullify the RTC order (14 February 2003) and Decision (16 November 2000).
- Ground: RTC Caloocan was precluded by the Quezon City injunction from issuing those orders.
Issues:
- Jurisdiction and Procedural Properness
- Whether petitioners could directly invoke the SC’s original jurisdiction for certiorari, prohibition, and declaratory relief, bypassing lower courts.
- Whether the petition for declaratory relief was proper under Rule 63, given its subject matter.
- Enforceability of Injunction
- Whether the Writ of Preliminary Injunction issued by RTC Quezon City binds RTC Caloocan City.
- Whether RTC Caloocan erred in denying petitioners’ Motion to Suspend Execution based on that injunction.
- Finality and Law of the Case
- Whether the issue of the injunction’s territorial applicability was already finally resolved by the CA and hence barred from relitigation (law of the case doctrine).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)