Title
Sy vs. Court of Appeals
Case
G.R. No. 95818
Decision Date
Aug 2, 1991
Unlawful detainer case proceeds despite pending ownership dispute; summary procedure upheld, appeal untimely, CA resolution annulled.

Case Summary (G.R. No. 95818)

Background of the Case

On November 8, 1988, the petitioner filed an unlawful detainer case against the private respondents in the Metropolitan Trial Court of Manila, asserting his right to possession of the disputed property. The private respondents countered on December 29, 1988, with a motion to dismiss, citing a pending action for annulment of sale and reconveyance before the Regional Trial Court of Manila. This related to their right to repurchase the property, which had been sold by a bank to the petitioner.

Proceedings in the Metropolitan Trial Court

At the preliminary conference, the trial court indicated that the case fell under the Rule on Summary Procedure and required both parties to submit position papers and affidavits. Subsequent motions by the private respondents to suspend the proceedings were denied. On November 27, 1989, the trial court ruled against the private respondents, ordering them to vacate the premises, pay back rentals, and cover attorney’s fees.

Respondents' Attempt to Appeal

The private respondents filed a motion for reconsideration, which was denied as a prohibited pleading under the Rule on Summary Procedure. An appeal filed on February 19, 1990, was also denied due course for being out of time due to the earlier denials of their motions. Following this, a writ of execution was issued to enforce the judgment.

Developments in the Regional Trial Court

The private respondents pursued an amended petition for certiorari and prohibition with the Regional Trial Court, challenging multiple orders from the Metropolitan Trial Court. They contended that the courts violated their rights by proceeding under the Rule on Summary Procedure while the ownership of the property was being litigated elsewhere.

Injunction Issued by Regional Trial Court

On June 18, 1990, the Regional Trial Court granted a preliminary injunction upon the private respondents’ posting of bond, preventing further eviction actions. The petitioner challenged this injunction, asserting a lack of jurisdiction for the Regional Trial Court to entertain the matter given that the decision from the Metropolitan Trial Court had become final and executory.

Court of Appeals Intervention

Following proceedings, the private respondents’ subsequent petition to the Court of Appeals sought to annul the Regional Trial Court's dismissal of their previous petition. A temporary restraining order was issued by the Court of Appeals, which ordered a return to the status quo regarding the property in dispute and the possessions taken by the sheriff.

Orders and Reactions from the Parties

The Court of Appeals issued further resolutions, wherein it required the petitioner to restore possession of the premises to the private respondents, while also mandating the return of seized goods. The petitioner argued that the Court of Appeals lacked jurisdiction, as the trial court’s decision had already become final and no appeal was properly filed.

Supreme Court Decision

The Supreme Court considered the jurisdictional issues surrounding the appeal processes, the applicabili

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