Case Summary (G.R. No. 192893)
Factual Background
Felicitas Enriquez and the Santos spouses were long-term occupants of adjacent lots on Laon Laan St. In 1976, the Santos spouses purchased a 200-square meter portion of land from the original owners, resulting in the issuance of Transfer Certificate of Title No. C-2892. Subsequently, it was revealed that Enriquez’s house was partially constructed on the land acquired by the Santos spouses, leading to a landlord-tenant relationship where Enriquez began paying monthly rent to the Santos family.
Ejectment Proceedings
In September 1982, the Santos spouses filed an ejectment suit against Enriquez in the Metropolitan Trial Court of Caloocan City, alleging non-payment of rent and the necessity of the property. The trial court ordered Enriquez to vacate the premises, a decision which was affirmed by the Regional Trial Court upon appeal.
Initial Civil Action by Petitioner
Simultaneously, Enriquez initiated her own legal action against the Santos spouses in 1983 for the annulment of the deed of sale and damages. However, this case was dismissed without prejudice, leading her to file a subsequent case solely for damages, which was tried in the Regional Trial Court of Caloocan City, concluding with a favorable decision for Enriquez in November 1984. This decision required the Santos couple to sell the land on which Enriquez’s house stood at a price of P100 per square meter.
Appeals and Judicial Review
The Santos spouses sought redress through a petition for certiorari, arguing that the trial court's decision should be overturned. The Intermediate Court of Appeals initially dismissed this petition on grounds of timeliness but later reinstated it after concluding that the late filing was due to excusable negligence. In August 1987, the appellate court eventually ruled in favor of the Santos spouses, thereby setting aside the earlier ruling of the Regional Trial Court.
Finality of Judgment
Following this appellate decision, Enriquez filed a motion for reconsideration, which was subsequently denied. The appellate court's decision entered final judgment in early February 1988, rendering it executory. Subsequently, in June 1988, Enriquez initiated a special civil action of certiorari under Rule 65, arguing that her previous resort to appeals was no longer viable because of the finality of the appellate decision.
Legal Reasoning
The Supreme Co
...continue readingCase Syllabus (G.R. No. 192893)
Case Background
- The case involves a special civil action of certiorari filed by Felicitas Enriquez against the Court of Appeals and private respondents Reynaldo and Natividad Santos.
- The petitioner challenges the decision of the Court of Appeals dated August 27, 1987, which overturned the ruling of the Regional Trial Court of Caloocan City dated November 26, 1984.
- The trial court had ordered the Santos couple to sell a 90-square meter portion of land occupied by Enriquez's house, along with awarding damages and attorney’s fees.
Factual Context
- Both petitioner Enriquez and the private respondents Santos were long-term tenants occupying neighboring lots on Laon Laan Street, Caloocan City, owned by Atty. Justo de Dios and Basilia Manotoc.
- On November 23, 1976, the Santos spouses purchased a 200-square meter portion of the land, which led to the issuance of Transfer Certificate of Title No. C-2892 in their favor.
- In 1978, it was found that Enriquez’s house was situated within the 200-square meter lot purchased by the Santos couple, prompting Enriquez to begin paying monthly rent to them.
Legal Proceedings
- On February 11, 1981, Enriquez filed a case for consignation due to the Santos's refusal to accept her rental payments, which was later dismissed.
- On September 9, 1982, the Santos filed an ejectment suit against Enriquez on