Case Summary (G.R. No. 75206)
Factual Background
On May 19, 1977, the late spouses Tomas and Francisca Galgala entered into a Memorandum of Agreement with Benguet Consolidated, Inc. acknowledging a cash shortage of PHP 772,419.34. To settle this debt, they agreed to sell two parcels of land in Baguio City and one parcel in Barrio Betag, La Trinidad, Benguet to the respondent. Following the execution of three deeds of sale on the same day, the titles for the properties were transferred to Benguet Consolidated, Inc. Despite the sale, the Galgalas continued to occupy the premises as lessees. However, after failing to pay rent, Benguet Consolidated initiated an unlawful detainer action in April 1979 against the Galgalas in the Municipal Trial Court of Baguio.
Judicial Proceedings
The Municipal Trial Court ruled in favor of Benguet Consolidated on November 26, 1983, ordering the Galgalas to vacate the premises and pay damages. This decision became final and executory due to the absence of an appeal. Meanwhile, on September 20, 1979, the Galgalas filed a separate action for annulment of the earlier Memorandum of Agreement and deeds of sale, claiming their consent was vitiated by force, duress, and fear, and sought reconveyance of the properties—a matter involving the same parcels at issue in the ejectment case.
Petition for Preliminary Injunction
After proceedings in the unlawful detainer case reached the execution stage, the heirs of the Galgalas filed a verified petition for a preliminary injunction to halt the enforcement of the ejectment ruling. The Regional Trial Court denied this petition on January 9, 1986, and their motion for reconsideration was similarly denied on February 14, 1986. Following this, the petitioners sought certiorari from the Intermediate Appellate Court, which also dismissed their petition.
Legal Issues and Holdings
The principal issue before the Supreme Court was whether the execution of the judgment from the ejectment case should be stayed pending the resolution of the annulment action concerning ownership of the properties. The Court reaffirmed the established legal principle that the judgment in an ejectment case pertains solely to possession, not title or ownership, as delineated in Section 7, Rule 70 of the Rules of Court. The Court emphasized that unlawful detainer proceedings are summary in nature and designed to expedite the protection of actual possession, thus the mere pendency of a suit for reconveyance does not stay execution of a possessory judgment.
Rationale for Decision
The Court was particularly concerned with the significant delay in the execution of the final judgment, noting that prolonging the process could result in further injustice to Benguet Consolidated, Inc. The petitioners' claim that the annulment suit might rend
...continue readingCase Syllabus (G.R. No. 75206)
Case Overview
- Petitioners: Helen Rose G. Cadelina and Esther G. Ymana, as substitutes for the deceased Tomas and Francisca L. Galgala.
- Respondents: Benguet Consolidated, Inc., Conrado H. Bueno, The Regional Trial Court of Baguio, Branch IV, The City Sheriff of Baguio City, and The Intermediate Appellate Court.
- Citation: G.R. No. 75206, September 05, 1989.
Factual Background
- A Memorandum of Agreement dated May 19, 1977, was executed by the Galgala spouses acknowledging a cash shortage of P772,419.34 incurred by Francisca Galgala during her employment as a medical assistant.
- The spouses agreed to repay the shortage by selling two parcels of land in Baguio City and one in Barrio Betag, La Trinidad, Benguet to Benguet Consolidated, Inc.
- Three deeds of sale were executed on the same day, transferring the parcels to the respondent.
- After redeeming the properties from two banks, Benguet Consolidated, Inc. had the titles transferred to its name.
- The Galgala spouses remained on the premises, initially due to their request for time to relocate and subsequently as lessees.
Legal Proceedings
- On April 11, 1979, Benguet Consolidated, Inc. filed an unlawful detainer suit against the Galgalas in the Municipal Trial Court of Baguio (Civil Case No. 6766) due to non-payment of rent.
- The trial court ruled in favor of the petitioner on November 26, 1983, ordering the Galgalas to vaca