G.R. No. L-13272 - Ocampo-Caniza vs. Martinez

Petitioner Trinidad Ocampo Caniza instituted an ejectment and unpaid rentals case (Civil Case No. 19123) against defendant Apolinario Velasco before the Municipal Court of Manila.
The judgment ordered Velasco to pay back rentals amounting to P2,237.30 up to January 31, 1952, monthly rentals of P750.00 from February 1, 1952 onward, and to vacate the premises.

On April 23, 1952, petitioner moved for the immediate execution of the judgment, which was granted on June 12, 1952, by the Municipal Court.
Defendant Velasco filed his notice of appeal on June 13, 1952, along with an appeal bond and docket fee, triggering the suspension of the writ of execution.
Velasco was given a period (initially three days, later extended to June 19, 1952) to file a supersedeas bond to stay execution.
Although Velasco failed to file the bond within the original period, he later filed a supersedeas bond on July 11, 1952, before the record was elevated to the Court of First Instance.

On July 21, 1952, Velasco petitioned the Court of First Instance for restoration of possession based on the supersedeas bond. The trial court granted this relief on July 30, 1952 by directing the Sheriff to restore possession to Velasco.
Petitioner then initiated certiorari proceedings in the Court of Appeals to annul the order restoring possession.
The Court of Appeals issued a writ of preliminary injunction, mandating status quo pending the final resolution of the petition for certiorari and denying an urgent motion for dissolution of that injunction.

On August 5, 1954, the trial court rendered a decision in Civil Case No. 17050 in favor of petitioner, further ordering Velasco to pay P6,159.74.
Subsequent alias writs of execution were issued, and motions to quash these writs were denied by the trial court, even as Velasco continued to challenge the proceedings.

On July 26, 1957, Velasco filed a petition for injunction in the Court of Appeals (CA-G.R. No. 20872R).
On October 31, 1957, the Court of Appeals ruled in favor of Velasco, holding that since the supersedeas bond was filed after the execution of the judgment, it did not serve to stay execution – particularly as execution, as presumed by the CA, encompassed both the restoration of possession and the payment of back rentals.

The CA assumed that the execution ordered by the Municipal Court included both the restoration of possession and the recovery of unpaid back rentals.
However, the actual execution only restored possession to the petitioner; the monetary aspect (back rentals) was not effected, as the back rentals remained unpaid and were otherwise the subject of the further trial court decision.

Petitioner sought certiorari from the Supreme Court to review the decision of the Court of Appeals.
The Supreme Court found that although the supersedeas bond was filed after the judgment’s execution for possession, it still had the effect of allowing Velasco to appeal without being compelled to pay the back rentals.
The Supreme Court thus reversed the Court of Appeals’ decision and imposed costs against respondent-defendant Velasco.

Whether a supersedeas bond filed after the execution of a judgment can effectively stay part of that execution, specifically concerning the payment of back rentals.

Should the supersedeas bond protect the appellant from being compelled to pay the monetary judgment (back rentals) while allowing the appeal to proceed?

Did the execution cover both the restoration of possession and the collection of back rentals, or was it limited only to the restoration of possession?

Can the defendant’s supersedeas bond be considered valid and effective if filed after the execution of the judgment but before the record was elevated to the Court of First Instance?

Whether the defendant, by previously relying on the bond’s validity in securing possession, can now contest its validity based on the timing of its filing.