Title
Santos-Yllana Realty Corp. vs. Spouses Deang
Case
G.R. No. 190043
Decision Date
Jun 21, 2017
A lessee's stall was padlocked for unpaid rent; damages claimed due to improper execution. SC ruled no liability for petitioner, deleting damages.
realty corporation
joint and solidary liability
damages

Case Summary (G.R. No. 190043)

Factual Background: The Ejectment Case and the Writ of Execution

Florentina, as lessee of Stall No. H-6, failed to pay rents and other charges. Petitioner therefore filed a Complaint for Ejectment with Damages before the Metropolitan Trial Court (MTC) of Angeles City on August 11, 1997, which was docketed as Civil Case No. 97-311 and raffled to Branch 1. On October 16, 1997, the MTC rendered a decision based on a Compromise Agreement executed by the parties. When Florentina did not comply with the compromise terms, petitioner filed a Motion for Execution on January 16, 1998. Respondents opposed the motion, claiming that the amount due had already been paid in full. After resolving the objections, the MTC issued an Order on February 20, 1998, granting the issuance of the writ of execution.

Respondents then moved to quash the writ on February 26, 1998. On the same date, Sheriff Allen Sicat of the RTC of Angeles City implemented the writ and padlocked the stall. The stall was nonetheless reopened within the same day by order of the MTC due to the pending Motion for Reconsideration. During the reconsideration hearings, respondents reiterated their claim of full payment and argued that execution had become moot. On June 3, 1998, the MTC upheld the writ and commanded immediate implementation. On June 5, 1998, Daniel Pangan, Sheriff III of the MTC, padlocked the stall and turned it over to petitioner, with acknowledgment by petitioner’s representative.

Initiation of the Damages Action in the Manila RTC

Aggrieved by the implementation of the writ, respondents filed a Complaint for Damages with Prayer for Injunctive Relief against petitioner and the sheriffs—Sicaty and Pangan—before the RTC of Manila, Branch 44, alleging that the writ was illegally implemented. Respondents claimed that important documents, checks, money, and bank books were locked inside the stall and could not be retrieved. They alleged that this prevented them from operating their business, caused business losses, and tarnished their goodwill. They prayed for P500,000 as actual damages, P250,000 as moral damages, P250,000 as exemplary damages, P100,000 as attorney’s fees, plus appearance fees and costs of suit.

RTC Findings and Liability

The trial court held that the undue haste by which the Angeles MTC issued and was executed the writ of execution violated respondents’ right to due process and impaired their opportunity to question the writ’s propriety. The RTC concluded that the enforcement was tainted with malice and bad faith. It also found that because of the illegal closure, respondents’ personal properties were detained inside the stall, which led to actual damages and unrealized profit from daily sales of P1,000, amounting to P500,000.

Accordingly, the RTC rendered judgment ordering petitioner and the sheriffs—jointly and severally—to pay respondents, namely P500,000 actual damages, P250,000 moral damages, P250,000 exemplary damages, P100,000 attorney’s fees plus appearance fees, and costs of suit.

Court of Appeals Ruling: Fault of Sheriffs, No Fault of Petitioner, Yet Damages Against Petitioner

Petitioner appealed. The Court of Appeals echoed the RTC observation that the sheriffs failed to comply with the notice requirement under Section 10(c) of Rule 39 during implementation of the writ of execution. The CA reasoned that, regardless of whether petitioner was ultimately entitled to possession, the sheriffs were still bound to observe the due process requirements set by Rule 39 in ejecting respondents.

At the same time, the CA relieved petitioner from responsibility for the manner of implementation. It stressed that petitioner, as the successful party in the ejectment case, had no shown participation in the sheriffs’ non-compliance with the notice requirement, and there was no showing that petitioner had a hand in the irregularity. Despite this, the CA sustained petitioner’s liability for damages, deleting only the award of actual damages for insufficiency of evidence. It reduced moral damages from P250,000 to P100,000, exemplary damages from P250,000 to P100,000, and attorney’s fees from P100,00.00 to P50,000.

Issue Before the Supreme Court

The sole issue was whether the Court of Appeals erred in sustaining moral and exemplary damages and attorney’s fees against petitioner despite its finding that petitioner had no participation in the implementation of the writ of execution.

Positions of the Parties

Petitioner argued that it could not be made jointly and severally liable for damages caused by the sheriffs, because it did not participate in the implementation. It relied on the CA’s own statements that it had no fault in the execution and that records failed to show any hand in the sheriffs’ non-compliance. It further contended that the CA’s damages awards lacked support in the decision’s body.

Respondents countered that the sheriffs acted upon petitioner’s order or instruction, and petitioner later benefited from the execution. They sought reinstatement of the RTC amounts for actual damages and the original amounts of moral and exemplary damages and attorney’s fees. Petitioner maintained its stance in reply that it had no involvement in the execution and added that the CA’s ruling had become final as to damages because respondents allegedly did not move for reconsideration or appeal the decision.

Supreme Court Ruling: Deletion of Petitioner’s Joint and Solidary Liability

The Supreme Court granted the petition. It held that petitioner’s joint and solidary liability had no factual and legal basis. It emphasized that it was undisputed that petitioner succeeded in the ejectment case, and thus it was entitled to seek execution of the MTC judgment under Section 19, Rule 70. The Court noted that Rule 70, Section 19 allows immediate execution upon motion in unlawful detainer or forcible entry cases, subject to conditions regarding stays of execution through appeal, supersedeas bond, and deposits.

The Court reasoned that petitioner elected to execute the MTC judgment; therefore, a disputable presumption under Rule 131, Section 3(ff) applied that petitioner had obeyed the law and rules. It cited Philippine Agila Satellite Inc. v. Usec. Trinidad-Lichauco for the proposition that a civil complaint for damages necessarily alleges a wrongful act or omission as basis for damages, and therefore the claimant bears the burden to overcome the disputable presumption by proving that the defendant abused rights and willfully intended to inflict damage. The Court concluded that, absent such proof and considering that petitioner had the sole prerogative to move for execution, the presumption of petitioner’s innocence of wrongdoing prevailed.

Incongruity Between the Court of Appeals’ Body and Fallo

The Supreme Court also examined the decision of the Court of Appeals and found an internal inconsistency between the CA’s body and fallo. While the CA found that the sheriffs erred in enforcing the writ with undue haste and without prior notice, it expressly stated that petitioner could not be faulted because it was the winning party in the ejectment case and records lacked any showing that petitioner had a hand in non-compliance with the notice requirement. The Supreme Court held that such categorical absolution in the body negated any liability of petitioner to respondents for the injuries caused by the sheriffs.

The Court acknowledged the rule that the operative part of a decision controls over the body in case of conflict, but it applied an exception: where the inevitable conclusion from the body clearly shows a mistake in the dispositive portion, the body prevails. Here, the CA’s findings in its discussion made it unjust and inequitable to hold petitioner liable despite its being categorically absolved.

Doctrinal Requirements for Moral and Exemplary Damages, Attorney’s Fees, and the Role of “Damnum Absque Injuria”

The Supreme Court further held that the awards could not stand. It reiterated that moral damages require proof of: (one) actual injury, (two) a culpable act or omission factually established, (three) proximate cause by the defendant’s wrongful act, and (four) a basis unde

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms