Case Summary (G.R. No. 116013)
Facts of the Case
The case originated from a civil ejectment action filed by Clemente Santiago against Ananias and Filemon Soco before the MTC of Malolos on February 7, 1983. After extensive proceedings, the MTC issued a decision favoring Santiago on January 21, 1991. This decision was subsequently affirmed in full by the Regional Trial Court (RTC) on May 9, 1991. Petitioners attempted to further appeal the RTC decision but failed to file a petition for review with the Court of Appeals within the prescribed period, despite being granted an extension of time. Following these events, Santiago moved for the issuance of a writ of demolition, prompting the MTC to issue an order on May 19, 1993, granting petitioners seven days to vacate the premises. On June 2, 1993, a writ of demolition was issued. Petitioners attempted to halt this action through a petition for certiorari and injunction, but their motions were ultimately denied.
Legal Issues Presented
The primary issue addressed was whether a new fact or circumstance could justify the non-enforcement of a final and executory judgment, specifically concerning the jurisdiction of the MTC and the implications of a favorable decision in a related civil case (Civil Case No. 562-M-90) that purportedly involved ownership of the property at dispute. Petitioners contended that the RTC decision in the later case should influence the execution of the earlier judgment, alleging that it created a substantial question regarding ownership.
Court's Ruling
The Supreme Court found that petitioners failed to demonstrate any reversible error by the Court of Appeals. They did not appropriately utilize the correct legal recourse, choosing to file a petition for review instead of a notice of appeal regarding the RTC’s dismissal of their certiorari action. The appellate court clarified that the dismissal order it reviewed was merely related to the certiorari petition and had the effect of a judgment. The Court highlighted that, according to existing jurisprudence, a writ of execution is generally mandatory once a judgment becomes final. It may be set aside only in exceptional circumstances where execution would be unjust given changed circumstances.
Examination of New Facts and Circumstances
The Court evaluated petitioners' claims that the ruling in Civil Case No. 562-M-90 constituted a new fact that would justify the suspension of the prior ejectment judgm
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Case Background
- This case originated from a protracted ejectment case filed by private respondent Clemente Santiago against petitioners Ananias and Filemon Soco in the Municipal Trial Court (MTC) of Malolos, Bulacan.
- The case has spanned thirteen years, appearing in multiple judicial venues before reaching the Supreme Court.
- The MTC rendered its judgment in favor of Santiago on January 21, 1991, which was later affirmed by the Regional Trial Court (RTC) of Malolos on May 9, 1991.
- Petitioners failed to file a timely petition for review with the Court of Appeals after the RTC’s ruling.
Procedural History
- The RTC upheld the MTC’s decision, establishing that the ejectment case was focused on material possession, which is distinct from ownership issues being addressed in another pending case.
- An order for demolition was issued by the MTC on May 19, 1993, after Santiago filed a motion for enforcement of the judgment.
- Petitioners sought to prevent this order by filing a petition for certiorari and injunction, which was dismissed by the RTC on July 20, 1993, and their