G.R. No. 117389 - Oblea vs. Court of Appeals

This is a petition for review on certiorari of the Court of Appeals’ decision dismissing a petition for certiorari and prohibition, as well as denying a prayer for a writ of preliminary injunction.
The case centers on the enforcement of an ejectment judgment and the controversial sale of a property with disputed title and possession.

The subject property is designated as Lot 1, Block 2, which was originally part of a mother lot covered by Transfer Certificate of Title (TCT) No. 26604.
TCT No. 26604, covering an area of 83,325 square meters, was initially registered in the names of Manuel Melencio (1/3), Pura Melencio (1/3), and Wilfredo Wico with Mariabelle M. Wico (1/3).
Subsequently, TCT No. 26604 was cancelled and replaced with TCT No. 65031 issued in the name of petitioner Ramon S. Melencio after a deed of sale executed by his now deceased father, Manuel Melencio.

On 6 June 1958, private respondent Juan S. Esteban acquired the subject lot from Mauricio Ramos, who claimed the property was obtained from Ursula Melencio, the administratrix of the estate of Manuel and Pura Melencio.
Petitioner Romeo V. Oblea initially leased a building on the subject lot from Marius Esteban (an alleged son of Juan S. Esteban) and later purchased the lot from him.

On 4 July 1991, Esteban filed an ejectment suit (Civil Case No. 10588) in the Municipal Trial Court (MTC) of Cabanatuan City against petitioner Oblea.
The MTC rendered a decision on 3 April 1992 in favor of Esteban, ordering Oblea to vacate the premises and pay rental arrears along with litigation expenses and attorney’s fees.
The Regional Trial Court (RTC) modified the decision on appeal on 26 March 1993, limiting the payment of rentals but sustaining the other aspects of the judgment.

Despite the pending litigation, on 3 June 1993, the registered owners sold the disputed lot to petitioner Oblea.
Petitioner Oblea, together with Ramon S. Melencio, Pura Melencio, Wilfredo Wico, and Mariabelle Wico, later filed an action for quieting of title (Civil Case No. 1536) contending that the deeds of sale executed by Mauricio Ramos and Ursula Melencio were null and void.

While the ejectment case remained final and executory, petitioners sought a petition for certiorari and prohibition, along with an application for a temporary restraining order and preliminary injunction to stop the execution of the ejectment judgment.
On 22 November 1993, the Executive Judge issued a temporary restraining order to halt the execution.
However, on 6 April 1994, Judge Adriano I. Tuason, Acting Presiding Judge of Branch 27, lifted and cancelled the restraining order, effectively allowing the execution of the ejectment judgment to proceed.

Petitioners elevated the case to the Court of Appeals, arguing that the subsequent sale to them constituted a “supervening event” that changed their right of possession and ownership.
On 27 September 1994, the Court of Appeals dismissed their appeal, finding that petitioners’ actions were merely designed to delay the execution of the judgment, which had become final and executory.

Whether the subsequent sale of the controversial lot to petitioners, purported as a "supervening event," alters the outcome of the ejectment judgment.

Does the acquisition of ownership after the judgment bar the execution of the ejectment order?

Whether the pending action for quieting of title, which addresses ownership, affects the jurisdiction of the trial court over the ejectment case that focuses on possession.

Can a pending quieting of title action divest the trial court of its power in executing the ejectment judgment?

Whether the petitioners’ arguments and the issuance and subsequent lifting of the temporary restraining order are sufficient to forestall the mandatory execution of the ejectment judgment.

Has petitioners’ litigation strategy unduly prolonged the implementation of a final and executory ruling?