Title
Soco vs. Court of Appeals
Case
G.R. No. 116013
Decision Date
Oct 21, 1996
Ejectment case final; Socos' claim of ownership in separate pending case deemed insufficient to halt execution of judgment.

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)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.