G.R. No. 75860 - Ping vs. RTC of Manila, Branch 40

Case Summary (G.R. No. 75860)

Factual Background

The dispute arose from ownership and possession of a parcel used by the respondents as the site of the Johnson Blacksmith & Machine Shop. The respondents had occupied and paid monthly rent of P500.00 since 1965. The property had been sold by a prior owner, T & L Development Corporation, to the petitioners. The petitioners instituted an ejectment action in the Metropolitan Trial Court to recover possession and obtain rents, while the respondents later filed a separate action for annulment of sale and reconveyance in the Regional Trial Court, claiming equitable grounds for redemption and alleging failure of the seller or buyers to act in good faith toward the tenants.

Prior Ejectment Proceedings and Appellate History

On October 25, 1983 the Metropolitan Trial Court rendered judgment in favor of the petitioners in the ejectment case, ordering respondents to vacate, to pay P5,000.00 per month in rentals from March 1, 1981 until they vacate less payments made in the meantime, and to pay P3,000.00 attorney's fees and costs. The RTC of Manila affirmed that decision on March 26, 1984 and on July 5, 1984 partially granted reconsideration by reducing monthly rentals to P500.00. The respondents appealed to the Intermediate Appellate Court, which questioned the validity of the MTC's promulgation date; this Court, in G.R. No. 70581, affirmed the decisions of the MTC and RTC as modified and reduced the rentals to the prelitigation rate of P500.00.

Nullification of Sale Proceeding in Civil Case No. 13911

While post-judgment execution of the ejectment was pursued, the respondents obtained a decision in Civil Case No. 13911 before the Regional Trial Court declaring the sale by T & L Corporation to the petitioners null and void on equitable grounds under Article 19, Civil Code, and ordering reconveyance by requiring the petitioners to sell 190 square meters to the respondents upon payment of P190,000.00. The RTC found that the respondents had continuously operated their business since 1965, had consistently paid P500.00 monthly rent, were not informed of the proposed sale when other tenants were, and had deposited P192,161.78 in trust for redemption. The petitioners moved for reconsideration, which was denied, and appealed to the Court of Appeals; that nullification case was pending at the time of this petition.

Proceedings in Branch 40 and the Injunction

After final judgment in the ejectment became executory and a motion for execution was filed, the Metropolitan Trial Court ordered execution. On April 28, 1986 Branch 40 of the Regional Trial Court of Manila issued a temporary restraining order and on May 16, 1986 denied the petitioners' motion to dismiss and directed issuance of a writ of preliminary injunction to enjoin implementation of the writ of execution arising from the MTC judgment. The RTC rested its action on the pendency and favorable outcome of Civil Case No. 13911.

Issues Presented

The principal legal question was whether a trial court may stay execution of a final and executory ejectment judgment, which this Court had affirmed, by issuing injunctive relief on the ground that a different trial court had rendered a subsequent decision nullifying the sale and title which underlies the ejectment claim. Ancillary issues concerned the propriety of enjoining execution despite the finality of the MTC and RTC judgments affirmed and modified by this Court.

Parties' Contentions

The petitioners asserted that the RTC of Branch 40 acted without or in excess of jurisdiction and gravely abused its discretion in issuing the injunction because the respondents' reconveyance judgment conferred no presently enforceable right and could not override the final ejectment judgment which this Court had affirmed. The petitioners observed that the annulment action had been presented to this Court in the earlier petition for review and that this Court had nonetheless denied reconsideration and entered judgment. The respondents contended that execution should be stayed because the RTC's decision in Civil Case No. 13911 vindicated their equitable right to redeem and reconveyance, and that ejecting them now would produce hardship should they prevail in that proceeding.

Supreme Court's Ruling

The Court granted the petition and set aside the RTC orders of April 28, 1986 and May 16, 1986. The Court ordered the Metropolitan Trial Court to immediately execute its decision in the ejectment case and refused to allow any motion for extension of time to file a motion for reconsideration of the present decision.

Legal Basis and Reasoning

The Court held that the pendency of a suit involving title or reconveyance does not preclude execution of a final judgment in an ejectment action where possession, not title, was the sole issue in the ejectment proceedings. The Court relied on Ramirez v. Bleza, 106 SCRA 187, and De la Cruz v. Court of Appeals, 133 SCRA 520, to restate that forcible entry and unlawful detainer actions are summary proceedings concerned with material possession and are independent

Case Syllabus (G.R. No. 75860)

Parties and Procedural Posture

ANG PING AND CARMEN PIMENTEL, PETITIONERS were plaintiffs in an ejectment action and later purchasers of the property in dispute.
JULIO AND ZENAIDA KO, RESPONDENTS were defendants in the ejectment action and plaintiffs in a separate nullification of sale and reconveyance case.
REGIONAL TRIAL COURT OF MANILA, BRANCH 40 issued a temporary restraining order and preliminary injunction to stay execution of an ejectment judgment and is the respondent court in the present petition for certiorari.
The ejectment judgment originated in the Metropolitan Trial Court of Manila, was affirmed by the Regional Trial Court, was the subject of appellate proceedings in G.R. No. 70581, and was finally resolved by the Supreme Court in a resolution on November 13, 1985.
The petitioners filed this petition after the Metropolitan Trial Court granted a motion for execution and after the respondent court enjoined implementation pending the outcome of Civil Case No. 13911.

Key Facts

The Metropolitan Trial Court rendered judgment for the petitioners in an ejectment case on October 25, 1983, ordering eviction, monthly rentals, attorney's fees, and costs.
The Regional Trial Court affirmed the MTC decision on March 26, 1984 and later reduced monthly rentals to P500.00 by order dated July 5, 1984.
The Supreme Court in G.R. No. 70581 validated the October 25, 1983 promulgation and affirmed lower court decisions as modified, fixing monthly rentals at P500.00.
The respondents had operated Johnson Blacksmith & Machine Shop in the disputed premises since 1965 and had paid P500.00 monthly rent.
The respondents filed Civil Case No. 13911 in the Regional Trial Court seeking annulment of sale and reconveyance and obtained a decision declaring the sale to ANG PING AND CARMEN PIMENTEL null and void and ordering reconveyance or sale of 190 square meters to the respondents for P190,000.00.
The respondents deposited P192,161.78 with a bank in trust for the petitioners as an alleged redemption payment in April 1981.
The respondent court issued a temporary restraining order on April 28, 1986 and an order on May 16, 1986 denying the petitioners' motion to dismiss and directing the issuance of a writ of preliminary injunction to stop execution.

Issues Presented

Whether the respondent court gravely abused its discretion or acted without or in excess of jurisdiction in issuing the temporary restraining order of April 28, 1986 and the May 16, 1986 order denying dismissal and directing a preliminary injunction.
Whether the respondent court committed grave abuse of discretion or acted without or in excess of jurisdiction in issuing a writ of preliminary injunction that deprived the petitioners of the fruits of their final and executory judgment in the ejectment case.

Contentions of the Parties

The petitioners contended that the n