Case Digest (G.R. No. L-49112) Core Legal Reasoning Model
Facts:
In Spouses Oscar and Haydee Badillo v. Triad Construction and Development Corporation and National Housing Authority, petitioners Spouses Badillo filed a forcible entry and ejectment case (Civil Case No. 263-94) in the Municipal Trial Court (MTC) of San Jose del Monte, Bulacan, alleging that the National Housing Authority (NHA) had intruded upon and developed a parcel of land in the Bagong Silang Resettlement Project that they claimed as their own. On February 1, 2000, the MTC ordered the NHA to vacate the land, return possession to the Badillos, pay rent at ₱10.00 per square meter per month, and shoulder attorney’s fees and costs. The NHA filed a Notice of Appeal on February 24, 2000 but did not pay the required appellate docket fees nor post a supersedeas bond within the 15-day reglementary period. The Badillos then secured a Writ of Execution (May 30, 2000) from the MTC to enforce the February 1 decision. The NHA’s motion to set aside the writ was denied, and it belatedly pa
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Case Digest (G.R. No. L-49112) Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Spouses Oscar and Haydee Badillo (petitioners) sued Triad Construction and Development Corporation and the National Housing Authority (NHA) for forcible entry and ejectment over a parcel within the Bagong Silang Resettlement Project (BSRP).
- The disputed land was part of the Tala Estate, reserved under Proclamation No. 843 (1971) and developed by NHA through a contract with Triad for mass housing.
- Trial Court Proceedings (MTC, San Jose del Monte)
- February 1, 2000 Decision: MTC ordered NHA to vacate, restore possession to petitioners, pay P10/sq m rent, attorney’s fees, litigation expenses, and costs.
- NHA filed Notice of Appeal on February 24, 2000 but did not timely pay appellate fees or post a supersedeas bond.
- May 23, 2000 Order and May 30, 2000 Writ of Execution: MTC, citing NHA’s failure to comply with Rules 40 and 70, issued execution writ and garnishment notice.
- Proceedings Before the Regional Trial Court (RTC), Bulacan
- NHA filed certiorari, prohibition, mandamus, injunction in RTC Branch 79; SEC 72-hour TRO issued; July 19, 2000 Order annulled MTC’s May 23 Order and writ, held appeal perfected despite nonpayment of fees and exempt from supersedeas bond.
- Records raffled to RTC Branch 11; October 23, 2000 Decision modified MTC Decision by deleting rental award but affirmed ejectment, possession, attorney’s fees, litigation expenses. NHA appealed to the Court of Appeals (CA).
- Consolidation and Supreme Court Review
- Two Rule 45 petitions (G.R. Nos. 143976 & 145846) consolidated by SC Resolution of October 17, 2001.
- SC heard issues on appellate fee payment, supersedeas bond exemption, annulment of MTC orders, and deletion of rental award.
Issues:
- Whether NHA’s failure to pay the appellate docket fee within 15 days warranted dismissal of its appeal.
- Whether NHA, as a government-owned and controlled corporation, is exempt from posting a supersedeas bond to stay execution.
- Whether RTC Branch 11 correctly deleted the award of rentals for use and occupation.
- Whether RTC Bulacan properly annulled the MTC’s May 23, 2000 Order, Writ of Execution, and Notice of Garnishment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)