Case Summary (G.R. No. 203022)
Background of the Case
This case arises from a petition for review on certiorari filed by Antonio Martinez against the Court of Appeals' Decision dated April 30, 2012, and Resolution dated July 25, 2012, which denied his petition for a writ of mandamus. At the core of the case is a prior ruling involving Natalia Realty, Inc. that resulted in an alias writ of execution issued by the Regional Trial Court of Antipolo City, which was executed, granting Martinez possession of certain parcels of land. The timeline of actions initiated by Martinez is crucial for understanding the subsequent legal proceedings.
Execution of Writ and Alleged Non-compliance
On February 20, 2004, the RTC issued an alias writ of execution that required certain lands to be delivered to Martinez and others. Deputy Sheriff Rolando Palmares subsequently executed a Certificate of Delivery of Possession stating the lands had been delivered successfully. An RTC order required that any remaining personnel from Natalia Realty be removed from the properties. However, Martinez alleged that Natalia Realty continued to refuse compliance, prompting him to seek further enforcement.
Motion for Further Writ and RTC Decision
Over two years later, on October 17, 2006, Martinez sought a new alias writ of execution, claiming that prior compliance was insufficient. The RTC denied his request on September 10, 2007, stating that since the prior writ was fully executed, there was no basis for issuing another one. Martinez then filed a petition for mandamus to compel the RTC to issue a new writ, which was eventually remanded to the Court of Appeals.
Court of Appeals Ruling
The Court of Appeals, in its April 30, 2012 ruling, deemed the petition for mandamus as premature, indicating that the RTC’s resolution of Martinez's pending motion should be awaited. The Court opined that if Natalia Realty was indeed non-compliant, contempt proceedings were the appropriate remedy rather than seeking a new writ through mandamus.
Issue for Resolution
The primary issue for the Supreme Court's resolution was whether the Court of Appeals was correct in dismissing Martinez's petition for mandamus due to lack of merit, taking into account the procedural requirements for seeking such extraordinary relief.
Supreme Court's Findings
The Supreme Court affirmed the Court of Appeals' decision, stating that the dismissal of the petition for mandamus was appropriate. The Court reiterated that mandamus is a remedy available only when there is no other adequate remedy
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Case Citation
- G.R. No. 203022
- Date of Resolution: December 03, 2014
- First Division, 749 PHIL. 353
Parties Involved
- Petitioner: Antonio Martinez
- Respondents:
- Hon. Ronaldo B. Martin, Presiding Judge of the Regional Trial Court of Antipolo City, Branch 73
- Rolando Palmares, Deputy Sheriff
- Natalia Realty, Inc.
Procedural History
- Petitioner filed a petition for review on certiorari challenging the Decision dated April 30, 2012, and the Resolution dated July 25, 2012, of the Court of Appeals (CA) in CA-G.R. SP No. 105092.
- The CA denied the petition for mandamus for lack of merit.
Factual Background
- The Regional Trial Court (RTC) of Antipolo City issued an alias writ of execution dated February 20, 2004, in favor of petitioner, granting possession of portions of two parcels of land covered by Transfer Certificates of Title (TCT) Nos. 31527 and 31528 (now TCT No. N-67845).
- On March 30, 2004, Deputy Sheriff Rolando Palmares executed a Certificate of Delivery of Possession, confirming that the land was delivered to petitioner and his co-parties.
- The RTC issued an Order dated July 27, 2004, directing the ousting of private respondent's guards and developers from the premises based on the alias writ.
- Deputy Sheriff Palmares reported on August 23, 2