Case Summary (G.R. No. 185407)
Background Facts
In Civil Case No. 94-71083, the Spouses Calidguid entered into a Compromise Agreement with the Spouses Jaime Lee. This agreement required the Calidguids to pay P2,520,000.00 to the Lees, which was subsequently approved by the Regional Trial Court (RTC). After the Calidguids failed to fulfill the payment terms, the Lees sought execution, resulting in the issuance of a Writ of Execution. The sheriff levied a property covered by Transfer Certificate of Title (TCT) No. 85561, and Jaime Lee acquired it at a public auction.
Redemption and Subsequent Proceedings
Sio Tiat King redeemed the property on October 30, 1996, securing a Certificate of Redemption as the assignee of the Calidguids. More than eleven years later, King filed a motion for a writ of possession, which was granted by the RTC. This prompted the Sheriff to issue a Notice to Vacate directed at the Calidguids and others claiming rights to the property.
Claim of Ownership and Motion to Quash
In response, the Lim siblings filed a Joint Affidavit of Third Party Claim, asserting they were registered owners of the property under TCT No. 122207. They subsequently moved to quash the writ of execution. The RTC initially scheduled a preliminary conference but then turned over possession of part of the property to King, leading the Lims to file an Extremely Urgent Motion to maintain the status quo.
Legal Actions Taken and Court Resolutions
Following various motions and hearings, including a petition for certiorari filed by the Lims, the RTC ultimately favored King but restricted the execution of the writ pending the resolution of ownership issues. On appeal, the Court of Appeals (CA) annulled the RTC's decision, finding that the writ of possession lacked legally necessary grounds due to the existence of conflicting property titles and the proper sequence of legal actions needed to resolve possession conflicts.
Court of Appeals Decision
The CA concluded that the writ of possession was improperly issued as the underlying Civil Case had already been executed and satisfied with the Certificate of Redemption. King's legal status as a "successor-in-interest" did not suffice to grant him rights over property when there were competing claims of ownership from the Lims. The CA emphasized due process, asserting that the Lims, being in possession, had legitimate claims that required judicial resolution before any eviction could occur.
Key Legal Principles Addressed
The case elucidated the following legal principles:
- Writ of Possession: Properly contingent upon the expiration of redemption rights and exclusively available to the purchaser or redemptioner in possession without adverse claims from third parties.
- Successors-in-Interest versus Redemptioners: The distinction between these terms is critical, as certain statutory rights must be legally enacted through appropriate legal means (e.g., ejectment suits) when property claims and ownership disputes arise.
- Judicial Process: Actual possession based on
Case Syllabus (G.R. No. 185407)
Background of the Case
- The case revolves around Civil Case No. 94-71083, where Spouses Victoriano and Evelyn Calidguid (Spouses Calidguid) entered into a Compromise Agreement, committing to pay P2,520,000.00 to Spouses Jaime Lee and Lim Dechu (collectively referred to as Spouses Lee).
- The agreement was approved by the Regional Trial Court (RTC) of Manila, Branch 4, on April 24, 1995.
- Due to non-compliance by the Spouses Calidguid, the Spouses Lee sought execution, leading to a Writ of Execution issued on August 2, 1995.
- The property of Spouses Calidguid, covered by Transfer Certificate of Title (TCT) No. 85561, was levied, and Jaime emerged as the highest bidder at the subsequent public auction.
- Sio Tiat King (King), as an assignee of Spouses Calidguid, redeemed the property on October 30, 1996, within the one-year redemption period, which resulted in the issuance of a Certificate of Redemption.
Developments Leading to the Petition
- Over 11 years later, King filed a motion for a writ of possession, which was granted by the RTC on January 22, 2008.
- A Writ of Possession was issued on January 25, 2008, and a Notice to Vacate was served to the Spouses Calidguid and others claiming rights over the property.
- On February 19, 2008, the Lims filed a Joint Affidavit of Third Party Claim, asserting own