Case Summary (G.R. No. 181930)
Factual and Procedural Background
On October 7, 2003, John Velez and Clarissa Velez initiated an ejectment complaint against Milagros Salting, leading to the Metropolitan Trial Court (MeTC) ruling in favor of the respondents on March 28, 2006. The MeTC ordered Salting to vacate the property and pay attorney’s fees. Subsequently, Salting opposed the execution of this decision and filed a separate action for annulment of the property sale against the heirs of Daniel B. Villamena, alleging fraud in the transfer of the property title.
Court Proceedings and Decisions
The Regional Trial Court (RTC) granted a preliminary injunction to Salting, which led the respondents to seek intervention through a special civil action for certiorari before the Court of Appeals (CA). The CA ruled that the RTC committed grave abuse of discretion by issuing the injunction and concluded that Salting did not possess a clear right over the property based on the MeTC decision.
Arguments Presented
Salting contended that the CA decision was flawed as it did not consider the improper service of the MeTC judgment because it was served to her deceased attorney. She argued that this service invalidated the finality of the judgment. She also asserted her existing right to possess the property and that the pendency of her annulment action justified the issuance of a preliminary injunction against the enforcement of the ejectment order.
Respondents' Counterarguments
In response, the respondents claimed the issue was moot due to the execution of the MeTC decision and asserted that the annulment action was distinct from the ejectment case. They contended that the MeTC decision’s finality did not impede her right to pursue the annulment of the property sale, emphasizing that the judgment in the ejectment case had been executed, and thus, further delay or relief was unwarranted.
Supreme Court’s Ruling
The Supreme Court concluded that service of the MeTC decision on Salting's counsel, even though deceased at the time, was valid and binding. The Court emphasized the duty of litigants to maintain communication with their counsel and the necessity for them to inform the court of any changes in representation. Consequently, the Court affirmed the CA's ruling that Salting did not have a clear legal right needing protection, thus negating grounds for a preliminary injunction.
Finality of the MeTC Decision
The Supreme Court clarified that an executory decision, such as the one rendered by the MeTC, can only be challenged through specific mechanisms like annulment on grounds of extrinsic fraud or lack of jurisdi
...continue readingCase Syllabus (G.R. No. 181930)
Case Overview
- Case Reference: G.R. No. 181930
- Decision Date: January 10, 2011
- Court: Supreme Court of the Philippines, Second Division
- Petitioner: Milagros Salting
- Respondents: John Velez and Clarissa R. Velez
- Legal Basis: Petition for review on certiorari under Rule 45 of the Rules of Court
Factual Background
- On October 7, 2003, respondents John and Clarissa Velez filed an ejectment complaint against petitioner Milagros Salting concerning a property covered by Transfer Certificate of Title (TCT) No. 38079, designated as Civil Case No. 2524.
- The Metropolitan Trial Court (MeTC), Branch LXXIV, of Taguig City ruled in favor of the respondents on March 28, 2006, ordering petitioner to vacate the property and pay attorney's fees and costs of suit. This decision became final and executory.
- Petitioner opposed the motion for execution filed by the respondents and subsequently initiated an action for Annulment of Sale concerning the same property, claiming she purchased it from the heirs of Daniel B. Villamena, and alleging fraudulent acts by them. This case was filed as Civil Case No. 70859-TG.
- The Regional Trial Court (RTC) issued a Temporary Restraining Order (TRO) against the execution of the MeTC decision, which prompted the respondents to file a special civil action for certiorari before the Court of Appeals (CA).
Procedural History
- The CA issued