G.R. No. 126462 - Natalia Realty, Inc. vs. Court of Appeals

Case Summary (G.R. No. 126462)

Key Individuals and Context
Petitioner: Natalia Realty, Inc.
Private Respondents: Antonio Martinez, Felipe Padua, Mario Perfecto, Hermito Salodega
Judicial Respondents: Court of Appeals Ninth Division (Justices Sandoval-Gutierrez, Austria-Martinez, Reyes); RTC Judges Querubin and Caballes
Intervenor: 359-A Multi-Purpose Cooperative
Subject Property: Two parcels in Sitio Banabas, Antipolo, Rizal (TCT Nos. 31527, 31528)

Petitioner’s Action and Trial Court Orders
On January 24, 1984, Natalia Realty filed an accion publiciana to recover possession of the two parcels. A TRO issued January 30, 1984 enjoined respondents from obstructing petitioner’s improvements. Private respondents claimed prior occupancy since before WWII. On August 26, 1991, the RTC (Branch 74) dismissed the case for failure to prosecute. On April 20, 1992, a different judge ordered surrender of parts of the property to respondents. Both orders became final when petitioner’s belated motions for reconsideration were denied.

Appeals and Certiorari Petitions
Petitioner filed a certiorari petition (CA-G.R. SP No. 30787) to challenge the dismissal; on June 18, 1993, the Court of Appeals Special Fifth Division dismissed it as untimely, a decision that became final October 20, 1993. Felipe Navarro, claiming to represent private respondents, sought a writ of execution in the trial court on December 27, 1993; the RTC denied it March 7, 1994, ruling the complaint was not a class suit and execution was barred by the dismissal order. Navarro’s appeal (CA-G.R. CV No. 44915) was dismissed February 6, 1995 because he was a disbarred lawyer without authority.

RTC Query and Court of Appeals’ Resolutions
In April 1995, Judge Querubin suspended execution and asked the Ninth Division which final orders to enforce. On June 27, 1995, the CA identified: (1) the August 26, 1991 dismissal; (2) the April 20, 1992 possession order; and (3) the June 18, 1993 CA resolution dismissing petitioner’s certiorari. Petitioner moved to set aside that CA resolution; on August 26, 1996, the Ninth Division reiterated its June 27, 1995 resolution and denied reconsideration, also requiring Judge Caballes (to whom the case had been re-raffled) to explain why he should not be held in contempt for failing to execute those final orders.

Issues Presented

Whether the Court of Appeals exceeded jurisdiction by answering a judge’s “personal letter-query.”
Whether it exceeded jurisdiction in ordering execution of both RTC orders and the CA decision.
Whether it exceeded jurisdiction in nullifying Judge Caballes’ November 6, 1995 order by reiterating its June 27, 1995 resolution.
Whether it abused discretion in merely noting petitioner’s July 10, 1995 motion.
Whether it abused discretion by threatening contempt against Judge Caballes.

Supreme Court Ruling on Finality and Duty to Execute
Under Rule 70 and settled jurisprudence, dismissal for failure to prosecute is with prejudice and final when no timely motion for reconsideration or appeal is made. The August 26, 1991 and April 20, 1992 orders and the June 18, 1993 CA resolution became final and executory. The CA’s February 6, 1995 resolution dismissing Navarro’s appeal likewise became final and ordered remand of the records for execution. Once final, execution is a ministerial duty of the RTC.

Legality of Judge’s Letter and CA Response
Although unorthodox and not provided in the Rules, a trial judge’s query to an appellate court is not prohibited. The CA’s response merely clarified which final, executory orders were to be enforced. This did not amount to grave abuse of discretion, nor did it violate due process: petitioner and respondents were notified and afforded opportunities to comment.

Jurisdiction over Execution and Contempt Power
The Ninth Division lawfully retained jurisdiction to enforce its final resolution. While a court’s authority to modify judgments ends with finality, its execution jurisdiction endures to ensure compliance. Ordering remand for execution and citing a judge in contempt for de

Case Syllabus (G.R. No. 126462)

Nature of the Petition

Petition for certiorari under Rule 65 of the Revised Rules of Court.
Seeks annulment of the Court of Appeals’ Resolution dated June 27, 1995 for excess of jurisdiction or grave abuse of discretion.
Also assails the CA’s June 19, 1996 Resolution reiterating its June 27, 1995 Resolution, and the August 26, 1996 Resolution denying petitioner’s motion for reconsideration.

Antecedent Facts

January 24, 1984: Natalia Realty, Inc. filed Civil Case No. 359-A in RTC Branch 74, Antipolo, Rizal, for recovery of possession of two parcels of land (TCT Nos. 31527 & 31528).
January 30, 1984: Trial court issued a TRO preventing respondents from obstructing petitioner’s work on the property.
Respondents claimed prior ownership and possession since before World War II.
August 26, 1991: Case dismissed for petitioner’s failure to prosecute (Order by Judge Ortille).
April 20, 1992: RTC, Branch 74 (Judge Nano), granted respondents’ motion ordering petitioner to surrender possession of portions of the property.
May 20, 1992: Petitioner moved to set aside both orders, alleging counsel’s excusable oversight.
March 26, 1993: RTC (Judge Rojas) denied reconsideration for belated filing; orders became final and executory.
April 23, 1993: Petitioner filed certiorari in CA (CA-G.R. SP No. 30787, Special Fifth Division).
June 18, 1993: CA dismissed petition for unreasonable delay and finality of orders.
October 11 & December 21, 1993: CA denied reconsideration and issued entry of judgment.
December 27, 1993: Felipe Navarro, claiming to represent respondents, moved for writ of execution in RTC Branch 74.
March 7, 1994: RTC (Judge Querubin) denied Navarro’s motion—held the complaint was not a class suit and a prior dismissal cannot restore possession.
June 13 & July 15, 1994: Navarro’s ancillary motion in CA Fifth Division denied for lack of jurisdiction.
February 6, 1995: CA Ninth Division dismissed Navarro’s appeal (CA-G.R. CV No. 44915) for being unauthorized (Navarro disbarred).
March 15, 1995: Respondents refiled motion for execution in RTC; petitioner opposed based on the Supreme Court’s decision in Natalia Realty vs. Department of Agrarian Reform as a supervening event.
April 17, 1995: Judge Querubin wrote to the Nin