Case Summary (G.R. No. 232202)
Antecedent Facts
The Metropolitan Trial Court (MeTC) initially dismissed a case against Orlando for unlawful detainer, characterizing it as prematurely filed and lacking a cause of action. However, upon appeal, the Regional Trial Court (RTC) overruled this dismissal, leading to a final judgment requiring Orlando to vacate the premises and pay compensation to MWSS. The RTC Clerk issued an Entry of Judgment confirming this decision's executory nature. Following a two-year period without action, MWSS sought a Writ of Execution, leading to further legal challenges from Orlando.
MeTC Ruling and Subsequent Actions
The MeTC granted the Writ of Execution over a decade after the finality of the RTC decision, stating that MWSS's delay was justified. Orlando opposed this motion, arguing that the execution violated the prescriptive period stated in the Rules of Court. The MeTC ultimately issued a Writ of Execution, which resulted in a Sheriff’s Notice to Vacate being served to Orlando.
RTC Ruling
Orlando, represented by Daniel, petitioned against the Writ of Execution in the RTC, claiming it was issued beyond the allowable time frame. The RTC dismissed the petition, asserting that MWSS had acted within its rights and the time-related concerns were unfounded, thus upholding the execution order.
Issue Presented
The primary issue before the Supreme Court was whether the RTC erred in upholding the Writ of Execution based on an incorrect interpretation of the Rules of Court regarding the enforceability of judgments.
Supreme Court Ruling
The Supreme Court granted the petition, emphasizing that the application for a Writ of Execution had exceeded the five-year period prescribed by Rule 39, Section 6, of the Rules of Court. The Court highlighted that both the movement by MWSS for execution and the issuance of the writ needed to occur within this temporal boundary to remain valid. As the Writ was issued more than twelve years post-judgment finality, the Court invalidated it, stating the MeTC lacked jurisdiction to issue the writ at that point.
Judicial Review and Legal Principle
The Court clarified the distinction between judicial remedies available under Rule 45 (review on certiorari) and Rule 65 (cer
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Case Citation
- G.R. No. 232202
- Date of Decision: February 28, 2018
- Reported in: 826 Phil. 967
Background of the Case
- The case originates from a petition for review under Rule 45 of the Rules of Court, contesting the Decision dated February 9, 2017, and the Order dated May 17, 2017, issued by the Regional Trial Court (RTC) of Quezon City, Branch 215, in Case No. R-QZN-16-03654-CV.
- The antecedent facts include a prior case, "Metropolitan Waterworks and Sewerage System v. Orlando A. Villareal and other persons claiming Rights Under Him," which was dismissed by the Metropolitan Trial Court (MeTC) for being prematurely filed and lacking a cause of action on October 30, 2000.
Procedural History
- The RTC reversed the MeTC's decision in 2002, ordering Orlando Villareal and others to vacate the premises and pay compensation.
- An Entry of Judgment was recorded on December 15, 2002, indicating that the RTC Decision became final and executory.
- On May 17, 2004, MWSS filed a Motion for Issuance of Writ of Execution, which prompted Orlando to file a Comment/Opposition citing compliance with R.A. No. 7279.
- The MeTC eventually issued an Order on July 28, 2014, granting MWSS's motion, and a Writ of Execution was issued on October 26, 2015.
Petitioner’s Argument
- Daniel A. Villareal, Jr., representing Orlando, f