Case Summary (G.R. No. 157866)
Applicable Constitutional and Legal Provisions
Reviewed under the 1987 Constitution. Batas Pambansa Blg. 129, Sections 17 and 18, govern the territorial authority of RTC branches. Rule 63 of the Rules of Court exclusively defines declaratory relief. The law of the case doctrine and rules on certiorari, prohibition, and writs of execution are also applied.
Background Facts
On January 31, 1997, Banaag filed an ejectment suit before the Metropolitan Trial Court (MeTC) Branch 49, Caloocan City, alleging that petitioners built and occupied houses without his consent. Petitioners counterclaimed occupancy rights since 1978 under a Certificate of Occupancy issued by Pinagkamaligan Indo-Agro Development Corporation (PIADECO).
Procedural History
Petitioners moved (July 1997) to suspend proceedings, relying on a preliminary injunction issued by RTC, Quezon City (November 10, 1997), but the MeTC (August 7, 1997) held it territorially inapplicable. The MeTC rendered judgment for Banaag (October 5, 1999). The RTC (November 16, 2000) and the Court of Appeals (April 25, 2002) affirmed. Execution pending appeal was granted (RTC order, September 12, 2001), and a writ of execution issued (September 27, 2001). Petitioners’ motion to suspend execution was denied (February 5, 2002; February 14, 2003). Execution was implemented March 5, 2003.
Issue of Territorial Enforceability of Injunction
Petitioners asserted the Quezon City RTC injunction should bind the Caloocan RTC. Under B.P. 129, Sec. 17 grants regional jurisdiction but Sec. 18 limits enforceability to the branch’s defined territorial area. The Court of Appeals and the RTC correctly held that an injunction does not extend beyond the issuing court’s territorial jurisdiction.
Application of the Law of the Case Doctrine
The binding effect of the Quezon City injunction was finally determined by the Court of Appeals decision (CA-G.R. SP No. 65076), which became final and executory on April 25, 2002. Under the law of the case doctrine, that ruling remains conclusive between the same parties on unchanged facts, precluding petitioners from relitigating the issue.
Issuance of Writ of Execution
Once a judgment is final and executory, the presiding judge must issue a writ of execution unless subsequent events
...continue readingCase Syllabus (G.R. No. 157866)
Facts
- Private respondent Avelino Banaag is the registered owner of Lot 4, Block 21, Maligaya Park Subdivision, Caloocan City, under Transfer Certificate of Title No. 196025.
- Petitioners Augusto Mangahas and Marilou Verdejo built houses on the property without Banaag’s knowledge or consent.
- Several demands to vacate were ignored; parties attempted conciliation before the Lupon Tagapayapa but failed.
Petitioners’ Assertions
- In their April 23, 1997 answer, petitioners denied unlawful deprivation and claimed long-term occupancy (since 1978) with the owner’s (PIADECO) conformity, evidenced by a Certificate of Occupancy.
- On July 10, 1997, they moved to suspend proceedings, invoking a Writ of Preliminary Injunction issued by the Quezon City RTC on November 10, 1997, covering occupants of the Tala Estate.
- They argued ejectment was inapplicable after one year of possession, respondent never had prior physical possession, and respondent’s title was allegedly fictitious.
Decisions of the MeTC and RTC
- MeTC Branch 49 (August 7, 1997): Denied the motion to suspend, ruling that the Quezon City injunction had no effect in Caloocan City.
- MeTC Decision (October 5, 1999):
• Upheld TCT No. 196025 as indefeasible proof of ownership and better right to possess.
• Held jurisdiction proper (case filed within one year of demand).
• Ordered petitioners to vacate, remove structures, pay P2,000/mo