Case Digest (Adm. Case No. 997)
Facts:
The case concerns a legal dispute between Ananias Soco and Filemon Soco (hereinafter referred to as the petitioners) against the Court of Appeals and Clemente L. Santiago (the respondent). The controversy originated from a civil case for ejectment (Civil Case No. 255) initiated on February 7, 1983, in the Municipal Trial Court (MTC) of Malolos, Bulacan, by Santiago against the petitioners. After a protracted legal battle lasting thirteen years, the MTC rendered its judgment in favor of the private respondent on January 21, 1991. The petitioners appealed to the Regional Trial Court (RTC) of Malolos, which affirmed the MTC decision on May 9, 1991. The petitioners' motion for reconsideration was subsequently denied on August 21, 1991, due to the interpretation of jurisdictional issues established in Ramirez vs. Bleza, which highlighted that ownership disputes could not impede the MTC’s authority over unlawful detainer cases.
The MTC's ruling became final and executory when
Case Digest (Adm. Case No. 997)
Facts:
- Background of the Ejectment Case
- Petitioners Ananias Soco and Filemon Soco were sued by private respondent Clemente Santiago in Civil Case No. 255 for ejectment, filed before the Municipal Trial Court (MTC) of Malolos, Bulacan.
- The MTC rendered a judgment in favor of the private respondent on January 21, 1991, which was subsequently affirmed in toto by the Regional Trial Court (RTC) on May 9, 1991.
- Petitioners’ motion for reconsideration before the RTC was denied on August 21, 1991, relying in part on the precedent set in Ramirez vs. Bleza.
- Finality and Subsequent Enforcement Actions
- Due to petitioners’ failure to file a proper petition for review with the Court of Appeals—even after an extension of time was granted—the RTC decision became final and executory.
- On May 19, 1993, the presiding judge of the MTC of Malolos, Branch II, issued an order giving petitioners seven (7) days to vacate the property under threat of a writ of demolition.
- Accordingly, on June 2, 1993, the writ of execution and the order of demolition were issued by the MTC.
- Petition for Certiorari and Injunction
- To forestall the execution of the demolition order, petitioners filed a petition for certiorari and injunction before the RTC, docketed as Civil Case No. 494-M-93.
- After a hearing, Civil Case No. 494-M-93 was dismissed on July 20, 1993, and a motion for reconsideration was subsequently denied on September 8, 1993.
- Alleged New Facts and Conflicting Litigation
- Petitioners contended that a favorable decision rendered in Civil Case No. 562-M-90 by the RTC of Malolos, Branch XVII, which dealt with the inventory and appraisal cum legitime distribution of the late Basilio Santiago’s properties, created a serious question of ownership.
- In this inventory/appraisal case, petitioners were among the plaintiffs, and the RTC ruled that the probated will of the decedent impaired their legitimes, awarding them a portion of the very parcel of land subject to the ejectment case.
- Petitioners argued that this favorable ruling, rather than merely presenting a serious question of ownership, constituted a new fact or circumstance that should prevent the MTC from issuing the writ of execution and demolition order.
- Procedural Posture and Mode of Appeal
- The petition for review was filed under Rule 45 of the Revised Rules of Court, challenging orders from the RTC (Civil Case No. 494-M-93) that dismissed the petition and denied the motion for reconsideration.
- The petitioners maintained that the new facts arising from the separate inventory/appraisal case should have an impact on the enforcement of the final ejectment judgment, despite the appellate forum’s prior rulings.
Issues:
- Whether the inferior court (MTC of Malolos, Bulacan) should be restrained from issuing and enforcing a writ of execution and order of demolition in an ejectment case when there is a favorable RTC decision in a separate inventory/appraisal and legitime completion case.
- Whether the existence of what petitioners claim as a “new fact or circumstance” (the favorable ruling in RTC Civil Case No. 562-M-90) is sufficient to justify the modification or non-enforcement of a final and executory judgment in the ejectment case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)