G.R. No. 53851 - Chua Huat vs. Court of Appeals

Case Summary (G.R. No. 53851)

Factual Background

The original action was Civil Case No. 74634 in the Court of First Instance of Manila, in which the plaintiffs (including Manuel Uy and Sons, Inc. and The Roman Catholic Archbishop of Manila) obtained a judgment dated 31 May 1972 ordering several defendants (including petitioners herein) to pay monthly sums and to vacate and surrender possession of certain properties, with removal or abandonment of improvements within sixty days. The trial court’s decision was affirmed by the Court of Appeals on 19 January 1977 and thereafter reviewed and denied by this Court in the related petitions for review.

Procedural History: Execution and Annulment Attempts

After the judgment became final and executory, plaintiffs moved for execution on 15 November 1978, and the trial court granted execution on 20 November 1978. On 21 November 1978 petitioner Chua Huat filed Civil Case No. 119751 seeking annulment of the judgment in Civil Case No. 74634 on the ground of lack of jurisdiction. Others filed a separate annulment action docketed as Civil Case No. 119884. Despite the pendency of those annulment actions, Branch XXVII ordered execution on 23 February 1979 and denied a motion to suspend proceedings on 5 April 1979, holding that a coordinate court could not interfere with execution.

Proceedings in the Court of Appeals and This Court (G.R. No. 53851)

Petitioners brought a petition for certiorari and prohibition with the Court of Appeals, docketed as C.A.-G.R. No. 09251 SP, to set aside the execution order and to prohibit enforcement pending resolution of their annulment action. The Court of Appeals denied relief on 29 February 1980, reasoning principally that the judgment in Civil Case No. 74634 was final and executory and that issues raised in the annulment attempt had already been decided, rendering the annulment action ineffectual to stay execution under the doctrines of finality and res judicata. Motions for reconsideration were denied on 30 April 1980 and 8 July 1980. Petitioners then brought the present petition to this Court.

Intermediate Appellate Court Action on the Annulment Suit

The trial court dismissed Civil Case No. 119751 by order dated 24 September 1979. Petitioner Chua Huat appealed that dismissal to the Intermediate Appellate Court, which affirmed the dismissal in its decision of 12 March 1984, holding that the jurisdictional issue raised in the annulment action had been already ruled upon in the prior litigation and was closed by res judicata and the finality of the prior appellate and Supreme Court proceedings.

Facts Leading to G.R. No. 63863: Condemnation and Demolition Orders

Separately, on 14 September 1982 Manuel Uy and Sons, Inc. requested the City Engineer of Manila to condemn several dilapidated structures occupied by petitioners at specified Pedro Gil and Paz Street addresses. The City Engineer issued notices of condemnation on 17 November 1982, stating the buildings were in dangerous condition and conditioning demolition on the Mayor’s confirmation as provided by Section 276 of the Compilation of Ordinances of the City of Manila. Inspection reports and Evaluation Committee memoranda showed structural deterioration ranging from more than fifty percent to as much as eighty percent.

Petitioners’ Contestation of Condemnation Findings

Petitioners obtained, by private inspection on 19 January 1983, a report dated 21 January 1983 from Civil Engineer Romulo C. Molas asserting that the buildings were structurally sound and had an economic life of at least eight years. Petitioners formally protested the notices of condemnation on 22 February 1983. One petitioner, Maria Gamboa, was informed on 26 April 1983 of a demolition order and told to vacate within fifteen days. Petitioners then filed a petition for prohibition with prayer for preliminary injunction and/or restraining order on 2 May 1983 against Mayor Ramon D. Bagatsing, City Engineer Romulo M. del Rosario, and Manuel Uy and Sons, Inc.

Administrative and Judicial Responses to the Condemnation Petition

This Court issued a Temporary Restraining Order on 9 May 1983 prohibiting enforcement with respect to Maria Gamboa’s building. The Mayor confirmed the condemnation orders on 6 July 1983, after which the City Engineer issued demolition orders on 12 September 1983 addressed to several petitioners directing vacation and removal within fifteen days. Respondents filed Comments asserting that the matters involved factual determinations proper to the Regional Trial Court, that the buildings posed hazards to life and public safety, that the power to condemn fell within the exclusive domain of the City Engineer and Mayor under the stated municipal ordinances and P.D. No. 1096, and that administrative remedies, including appeal to the Secretary of Public Works under the Implementing Rules (Section 5.3), were available and unexhausted.

Issues Presented to the Supreme Court

The consolidated proceedings presented two principal issues: first, whether the Court of Appeals erred in denying petitioners’ C.A. petition and in refusing to stay execution of a final and executory judgment where petitioners had filed an annulment action attacking jurisdiction (G.R. No. 53851); and second, whether the City Engineer and the Mayor committed grave abuse of discretion amounting to lack of jurisdiction in issuing the condemnation and demolition orders and whether certiorari under Rule 65, Rules of Court was the proper remedy when administrative remedies were available (G.R. No. 63863).

Petitioners’ Arguments

Petitioners argued that execution of Civil Case No. 74634 should be stayed because Civil Case No. 119751 for annulment raised lack of jurisdiction, which justified suspension of execution. Petitioners also contended that the condemnation and demolition orders were erroneous and arbitrary because the buildings were structurally sound per their private engineer’s report, and that there was no plain, speedy, and adequate remedy to prevent imminent demolition.

Respondents’ Contentions

Respondents countered that the judgment in Civil Case No. 74634 was final and executory, that petitioners had repeatedly litigated the jurisdictional point and were barred from re-litigating it by res judicata, and that the Court of Appeals acted properly in ordering execution. As to condemnation, respondents maintained that the City Engineer and Mayor acted within their authority under Sections 275 and 276 of the Compilation of Ordinances of the City of Manila and Section 215 of P.D. No. 1096, that the condemnation resulted from thorough inspections showing defects up to eighty percent, that petitioners’ protest was untimely under Section 276, and that administrative appeal procedures, including appeal to the Secretary under the Implementing Rules (Sections 5.1, 5.3, 5.6), remained available and unexhausted.

The Court’s Disposition

The Supreme Court dismissed both petitions for lack of merit. The Court held that G.R. No. 53851 was frivolous because petitioners pursued repetitive and dilatory tactics to frustrate execution of a long-final judgment, and that G.R. No. 63863 failed because petitioners did not establish grave abuse of discretion by the City Engineer or Mayor and had not exhausted administrative remedies. The Court ordered dismissal of the consolidated cases with treble costs against petitioners.

Legal Reasoning on the Finality and Annulment Issues (G.R. No. 53851)

The Court emphasized that the decision in Civil Case No. 74634 had been affirmed by the Court of Appeals and reviewed by this Court in earlier petitions, and that petitioners repeatedly raised the same jurisdictional issue in successive proceedings in a manner designed to delay execution. The Court applied the doctrines of finality and res judicata, citing authority that issues once finally decided by a court of competent jurisdiction are closed to subsequent litigation between the same parties, and rejecting petitioners’ attempt to relitigate jurisdiction by changing procedural form. The Court also invoked precedents admonishing lawyers against filing meritless pe

Case Syllabus (G.R. No. 53851)

Parties and Procedural Posture

Petitioners were occupants of several buildings in Paco, Manila who sought relief by separate petitions consolidated by the Court.
Respondents included The Honorable Court of Appeals, Judge Elviro Peralta, Sheriff of Manila, The Roman Catholic Archbishop of Manila, Manuel Uy and Sons, Inc., Hon. Ramon D. Bagatsing, and Romulo M. del Rosario in their respective capacities.
The cases consolidated three separate petitions, primarily G.R. No. 53851, a petition for review on certiorari, and G.R. No. 63863, a petition for prohibition with prayer for preliminary injunction and/or restraining order.
The writs sought to prevent execution of a final judgment in Civil Case No. 74634 and to restrain condemnation and demolition orders issued by city officials of Manila.
The Court required comments, received memoranda from the parties, consolidated the cases on 4 January 1984, and gave due course to the petitions on 30 July 1986.

Key Facts

Civil Case No. 74634 resulted in a decision dated 31 May 1972 ordering possession recovery, monthly payments, and removal of improvements, and the decision was affirmed by the Court of Appeals on 19 January 1977.
The judgment in Civil Case No. 74634 became final and executory and was the subject of an execution order granted by the trial court on 20 November 1978.
After finality, one petitioner filed Civil Case No. 119751 and others filed Civil Case No. 119884 seeking annulment of the 1972 judgment on the ground of lack of jurisdiction.
The trial court ordered execution despite the pendency of the annulment suits and denied motions to suspend execution, which prompted an appeal to the Court of Appeals in C.A.-G.R. No. 09251 SP.
On 14 September 1982 Manuel Uy and Sons, Inc. requested condemnation of the petitioners' buildings and the City Engineer issued notices of condemnation on 17 November 1982, citing structural deterioration.
Petitioners obtained a private inspection report dated 21 January 1983 asserting structural soundness, formally protested the condemnation on 22 February 1983, and several demolition orders followed after mayoral confirmation on 6 July 1983.

Prior Decisions

The trial court rendered the dispositive judgment in Civil Case No. 74634 on 31 May 1972.
The Court of Appeals affirmed that judgment in C.A.-G.R. No. 51337-R on 19 January 1977.
Petitions for review in G.R. No. L-47603 and G.R. No. L-48649 were denied by this Court.
The Court of Appeals in C.A.-G.R. No. 09251 SP denied the petition to stay execution on 29 February 1980 and denied subsequent motions for reconsideration on 30 April 1980 and 8 July 1980.
Civil Case No. 119751 was dismissed by the trial court on 24 September 1979 and that dismissal was affirmed by the Intermediate Appellate Court in its decision of 12 March 1984.

Issues Presented

Whether the pendency of Civil Case No. 119751 for annulment of judgment justified the stay of execution of the final judgment in Civil Case No. 74634.
Whether the issuance and subsequent confirmation of condemnation and demolition orders by the City Engineer and the Mayor respectively amounted to grave abuse of discretion or lack of jurisdiction warranting certiorari.
Whether Rule 65 relief was available notwithstanding alternative administrative remedies and appellate remedies.

Petitioners' Contentions

Petitioners contended that the trial court lacked jurisdiction over Civil Case No. 74634 because the action was really for unlawful detainer rather than accion publiciana and the judgment was therefore void.
Petitioners argued that