ALPA-PCM, Inc. v. Bulasao

G.R. No. 197124 (March 19, 2012)

SC upheld RTC's writ execution in ALPA-PCM's case, denying appeal and imposing treble costs.

Facts:

In 2004, private respondents Vincent, Juliet, and Susana Bulasao (the Bulasaos) initiated an unlawful detainer action against ALPA-PCM, Inc. (ALPA-PCM) before the Municipal Trial Court (MTC) of La Trinidad, Benguet. The MTC ruled in favor of the Bulasaos, ordering ALPA-PCM to vacate the property in question in a decision dated May 31, 2006. ALPA-PCM appealed this decision to the Regional Trial Court (RTC) of La Trinidad, Benguet, Branch 62, which affirmed the MTC's ruling on July 31, 2007.

Following the RTC's decision, the Bulasaos filed a motion for the issuance of a writ of execution on August 13, 2007. ALPA-PCM, on the other hand, filed a motion for reconsideration of the RTC's decision on August 16, 2007. The RTC denied ALPA-PCM's motion for reconsideration on October 25, 2007, and subsequently granted the Bulasaos' motion for execution on November 21, 2007. ALPA-PCM sought reconsideration of this order, which was denied on February 5, 2008, leading to the issuance of a writ of execution on February 12, 2008.

ALPA-PCM then filed a separate certiorari petition with the Court of Appeals (CA), arguing that the RTC's orders authorizing execution were null and void due to the pending appeal. The CA dismissed ALPA-PCM's petition on January 6, 2011, finding no grave abuse of discretion by the RTC in granting the Bulasaos' motion for execution. ALPA-PCM subsequently filed a petition for review on certiorari with the Supreme Court, which was denied on July 6, 2011.

Legal Issues:

  1. Whether the RTC had the jurisdiction to grant execution pending appeal despite the filing of a motion for reconsideration by ALPA-PCM.
  2. Whether the RTC was required to provide good reasons for granting the writ of execution pending appeal.

Arguments:

  • Petitioner (ALPA-PCM):

    • ALPA-PCM contended that the RTC acted without jurisdiction in granting the writ of execution while its motion for reconsideration was pending. It argued that the RTC must provide good reasons for execution pending appeal, as stipulated in Section 2, Rule 39 of the Rules of Court. ALPA-PCM cited the case of JP Latex Technology, Inc. v. Ballons Granger Balloons, Inc., asserting that execution pending appeal is improper when a motion for reconsideration is still unresolved.

  • Respondents (Bulasao Family):

    • The Bulasaos maintained that the RTC had residual jurisdiction to grant execution pending appeal, as provided under Section 8, Rule 42 of the Rules of Court. They argued that the RTC's order was valid since ALPA-PCM had not yet filed its petition for review with the CA at the time the RTC granted the motion for execution.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the CA's dismissal of ALPA-PCM's petition and denied its motion for reconsideration. The Court reasoned that the RTC retained residual jurisdiction to order execution pending appeal as long as the CA had not yet given due course to the petition for review. The Court clarified that ALPA-PCM's motion for extension of time to file a petition for review did not equate to an actual filing of the petition, thus allowing the RTC to proceed with the execution.

The Court also addressed ALPA-PCM's argument regarding the necessity of providing good reasons for execution pending appeal. It emphasized that actions for unlawful detainer are governed by the Revised Rules on Summary Procedure, which mandates that decisions rendered in such cases are immediately executory without the need for further justification, even if an appeal is pending.

The Court further noted that the Bulasaos' motion for execution was not premature, as the RTC acted on it only after resolving ALPA-PCM's motion for reconsideration. The Court reiterated the importance of expeditious resolution in unlawful detainer cases and highlighted the potential for sanctions against parties who misuse judicial remedies to delay execution.

Significant Legal Principles Established:

  1. The RTC retains residual jurisdiction to grant execution pending appeal in unlawful detainer cases, even when a motion for reconsideration is pending, provided that the CA has not yet given due course to the appeal.
  2. Decisions in unlawful detainer cases are immediately executory under the Revised Rules on Summary Procedure, without the need for the RTC to provide additional justification for execution pending appeal.
  3. Misuse of judicial remedies to delay execution may result in sanctions, including the imposition of costs against the offending party.