Case Digest (G.R. No. 209672-74)
Facts:
Edmund Sia v. Wilfredo Arcenas, Fernando Lopez, and Pablo Rafanan, G.R. Nos. 209672-74, January 14, 2015, the Supreme Court First Division, Perlas‑Bernabe, J., writing for the Court.Due to real property tax delinquencies of Panay Railways, Incorporated (PRI) for 1992–1996, the City Treasurer of Roxas City conducted a tax-auction of the subject lots; Edmund Sia (petitioner) was the highest bidder and received a Certificate of Sale dated December 20, 1996. The City Treasurer, however, refused to issue a Final Bill of Sale after the one-year redemption period elapsed; then-Mayor Juliano Alba issued Executive Order No. 08‑97 nullifying the auction. Petitioner filed a special civil action seeking annulment of EO 08‑97, mandamus, and damages before the Regional Trial Court (RTC), Branch 17 (docketed SCA No. V‑7075), asking in effect that the City Treasurer be compelled to issue the Final Bill of Sale.
On March 21, 2001, RTC Branch 17 ruled for petitioner, declaring the auction valid and ordering the City Treasurer to issue the Final Bill of Sale. The Court of Appeals affirmed, and PRI's appeal to the Supreme Court was dismissed for lateness and failure to pay fees; the judgment became final and executory on October 23, 2007. Petitioner moved for execution (Dec. 21, 2007); an initial Writ of Execution was issued on February 28, 2008 by the RTC, Branch 15. The City Treasurer nonetheless claimed petitioner still owed P2,394,526.44 in taxes that accrued during the pendency of the case.
Instead of paying, petitioner filed a Motion to Divest PRI of Title (Mar. 31, 2008). RTC Branch 15 granted the motion on June 10, 2008 and held petitioner could not be held liable for taxes prior to issuance of the Final Bill of Sale. Petitioner then sought delivery of possession; the court issued a Writ of Possession on June 19, 2009 and a Writ of Demolition on August 28, 2009. Respondents, occupying the lots as PRI lessees, moved to quash (Sept. 1, 2009), arguing that the underlying judgment was in mandamus and execution of such special judgments is limited to directing compliance and contempt under Section 11, Rule 39 and Section 9, Rule 65 of the Rules of Court. RTC Branch 15 denied the motion to quash (Sept. 18, 2009) and denied reconsideration (Oct. 15, 2009).
Respondents filed separate petitions for certiorari with the Court of Appeals (consolidated), which, in a Decision dated January 31, 2013, set aside the Writ of Possession and the Writ of Demolition and directed enforc...(Pro-only)
Issues:
- Did the Court of Appeals correctly declare the Writ of Possession (June 19, 2009) and the Writ of Demolition (August 28, 2009) null and void and direct the RTC Branch 15 to enforce the Writ of Execution dated February 28, 2008 in accordance with Section 11, Rule 39 in relation to Section 9, Rule 65 of the Rules of Court?
- Did RTC Branch 15 exceed its authority in enforcing the judgment in SCA No. V‑7075 by issuing writs of possession and demolition vesting poss...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)