Case Digest (G.R. No. 204997)
Facts:
The case is Edilberto "Eddie" Pineda, et al. v. Abelardo C. Miranda, et al., G.R. No. 204997, promulgated August 04, 2021, the Supreme Court Second Division, Hernando, J., writing for the Court. Petitioners are numerous residents of Barangay Sindalan, San Fernando, Pampanga (collectively, petitioners); respondents are Abelardo C. Miranda, Elias C. Miranda, and Carmencita D. Miranda (collectively, respondents), the putative registered owners of the subject lots.On October 27, 1997 respondents filed a Complaint for Unlawful Detainer with the Municipal Trial Court (MTC) of San Fernando. On December 15, 1998 the MTC (Branch 3) rendered judgment for respondents ordering delivery of possession, payment of compensation at P200 per lot per month, attorney’s fees and costs. Petitioners appealed to the Regional Trial Court (RTC), Branch 42, which on May 17, 1999 affirmed the MTC decision but modified damages and attorney’s fees (rental P100 per lot, attorney’s fees P10,000). Respondents moved for issuance of a writ of execution, granted February 14, 2000.
When the writ had not been executed within five years, respondents filed on May 9, 2006 a Complaint for Revival of Judgment (Civil Case No. 13259) in the RTC, Branch 43 (a co-equal branch), asserting the judgment remained enforceable by action within the ten-year prescription under the Civil Code. Petitioners countered with an Answer, then filed a Motion to Quash the writ (July 20, 2006). The MTC quashed the writ on November 15, 2006, reasoning that after five years execution requires revival by independent action.
Petitioners also sought remedies in the Court of Appeals (CA): a Petition for Annulment of Judgment (dismissed by the CA Special Seventeenth Division for lack of jurisdiction over annulment of MTC judgments) and a Petition for Mandamus and Prohibition in CA-G.R. SP No. 111554 to compel RTC Branch 43 to give due course to their Notice of Appeal. The CA Former First Division granted mandamus on November 2, 2010 and directed the RTC to give due course to petitioners’ August 12, 2009 Notice of Appeal. Meanwhile, the RTC Branch 43 on March 20, 2009 had ruled for respondents and revived the RTC Branch 42 decision; its denial of petitioners’ motion for reconsideration was on July 23, 2009. The CA Fifteenth Divi...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the RTC Branch 43 decision reviving the RTC Branch 42 judgment and in denying petitioners’ appeal pursuant to Section 6, Rule 39 of the Rules of Court?
- Were petitioners’ alternative remedies — Motion to Quash the Writ of Execution, Petition for Annulment of Judgment, and Petition for Mandamus and Prohibition — proper and sufficient to defeat respondents’ ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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