G.R. No. 127936 - Panado vs. Court of Appeals

A series of cases arose concerning the ownership and possession of a parcel of land involving petitioners (Thelma C. Panado, Martina C. Rellorta, Manuel Cristobal, and others) and multiple private respondents (including Hernando Cortes and members of the Cortes family).
The disputes were litigated in three related actions:

Civil Case No. 3951 – an action for recovery of possession and ownership.
Civil Case No. 4187 – an action for quieting of title with damages.
Civil Case No. 1142 – an action for forcible entry initiated by private respondents.

Petitioners filed an amended complaint on July 27, 1989, against respondent Hernando Cortes.
The Regional Trial Court (RTC) of Kalibo, Aklan, presided over by Judge Sheila Martelino-Cortes dismissed the complaint for failure to prosecute; the counterclaim was waived and likewise dismissed.

Petitioners subsequently instituted a complaint for quieting of title with damages on May 9, 1990, which was later amended on November 26, 1990.
The RTC dismissed the case on April 10, 1991, on the grounds of res judicata and forum shopping by the petitioners, with costs imposed against them.
A motion for reconsideration was filed and denied, leading to an appeal to the Court of Appeals (CA), which on October 28, 1993, affirmed the dismissal and imposed costs against the appellants.
Judgment was entered on July 13, 1994, after which private respondents filed a motion for execution of judgment.
Petitioners opposed the motion on the basis that the dispositive portions of the earlier dismissal left nothing to execute.
On March 3, 1995, an order was issued for the issuance of a writ of execution in Civil Case No. 4187, based on the final and executory nature of the CA’s decision.

In response to the issuance of the writ of execution in Civil Case No. 4187, petitioners filed a Petition for Certiorari before the CA challenging the writ.
On April 28, 1995, the CA issued a Temporary Restraining Order (TRO) directing the public respondents (the RTC judge and the sheriff) to temporarily desist from enforcing the assailed order and writ of execution.

On December 28, 1995, petitioners filed a separate petition within the same proceedings before the CA to declare, as a matter of contempt, the private respondents for allegedly entering the disputed property in violation of the TRO.
Notably, petitioners intermingled issues relating to the enforcement of two writs (one arising from Civil Case No. 4187 and another from Civil Case No. 1142 for forcible entry), although the latter had never been disputed in these proceedings.
The petitioners also referenced alleged defects in the execution of judgments and questioned the authenticity of the sheriff’s return in the forcible entry case, despite these issues being irrelevant to the petition at hand.

Whether or not the Respondent Court committed grave abuse of discretion in finding that private respondents cannot be held in contempt of court.
The issue was framed as one of grave abuse of discretion; however, the petition for review under Rule 45 is limited to correcting reversible errors, not addressing allegations of grave abuse.

Whether the TRO issued by the Court of Appeals, which restrains only the public respondents from executing the writ in Civil Case No. 4187, imposed any duty upon the private respondents such that their entry into the disputed property could amount to contempt.
Whether petitioners improperly intermingled issues regarding the issuance and execution of writs related to separate actions, specifically questioning the substantive merits of a final and executory judgment and the validity of a writ in a forcible entry case.
Whether petitioners’ additional arguments – including alleged defects in the Writ of Execution in Civil Case No. 1142, and claims about the factual ownership of the property – are procedurally and materially relevant to the present petition.