Mayuga v. Court of Appeals

G.R. No. 123899 (August 30, 1996)

SC upheld RPN Realty eviction; negligence of counsel doesn't exempt clients, deemed professional squatters.

Facts:

This case involves a dispute over a parcel of land located at Granate Street, Sta. Ana, Manila, which was the subject of an action for recovery of possession filed by RPN Realty, Inc. against several petitioners, including Rosalinda Mayuga and others. RPN Realty claimed to have purchased the land in 1992, for which Transfer Certificates of Title Nos. 207569 and 207570 were issued in its name. The petitioners, who had constructed houses on the property, denied RPN Realty's ownership, asserting that they and their predecessors had been bona fide tenants of the former owner for sixty years and had been paying rent. They also claimed that the land was declared by the National Housing Authority (NHA) as part of the Urban Land Reform Zone, and they had been issued NHA identification numbers.

The Regional Trial Court (RTC) ruled in favor of RPN Realty, ordering the petitioners to vacate the premises and remove their houses. The petitioners did not appeal this decision, which became final and executory. Subsequently, they filed a "Motion for Relief from Judgment," claiming they were unaware of the RTC's decision due to their former counsel's negligence. This motion was denied, and RPN Realty sought a special order for demolition, arguing that the petitioners were professional squatters with sufficient income for legitimate housing, thus exempting them from the eviction procedures under Republic Act No. 7279.

The RTC granted RPN Realty's motion, declaring the petitioners as professional squatters and issuing an alias writ of execution for their eviction and demolition of their houses. The petitioners then filed a petition for mandamus and certiorari with the Court of Appeals, which issued a temporary restraining order but later dismissed the petition and affirmed the RTC's decision.

Legal Issues:

  1. Whether the Court of Appeals erred in affirming the RTC's decision without the records being elevated on appeal.
  2. Whether the petitioners were entitled to relief from judgment due to their former counsel's negligence.
  3. Whether the RTC acted within its jurisdiction in declaring the petitioners as professional squatters and exempting RPN Realty from the eviction procedures under R.A. No. 7279.

Arguments:

Petitioners' Arguments:

  • The Court of Appeals erred in ruling on the merits of the case when the action was a special civil action for mandamus and certiorari, not an appeal.
  • They contended that the RTC's order denying their motion for relief from judgment was not properly before the Court of Appeals.
  • They argued that the failure of their former counsel to inform them of the adverse decision constituted excusable negligence, warranting relief from judgment.

Respondent's Arguments:

  • RPN Realty contended that the petitioners were professional squatters and thus not entitled to the protections under R.A. No. 7279.
  • They argued that the petitioners' appeal was correctly dismissed as they failed to show that the RTC neglected its duty regarding the notice of appeal.
  • RPN Realty maintained that the RTC acted within its jurisdiction in issuing the alias writ of execution and demolition order.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, affirming the RTC's ruling. The Court reasoned that the petitioners failed to prove their entitlement to relief from judgment, as the negligence of their former counsel was inexcusable and did not justify setting aside a valid judgment. The Court emphasized that notice sent to a counsel of record is binding upon the client, and the failure to inform the client of an adverse judgment does not warrant relief.

The Court also clarified that the petitioners' appeal from the order denying relief from judgment was deemed perfected, and the RTC's order did not expressly deny their appeal. The Court of Appeals correctly treated the petition as an appeal and confirmed the existence of the judgment on the merits, which had long become final and executory.

Furthermore, the Court ruled that execution proceedings are not automatically stayed by the filing of a petition for relief from judgment, and the petitioners did not secure a preliminary injunction to stay the execution. The Court reiterated that the RTC had a ministerial duty to issue the writ of execution once the judgment became final.

Significant Legal Principles Established:

  • The binding nature of notices sent to counsel of record on clients.
  • The inexcusable negligence of counsel does not justify relief from a valid judgment.
  • Execution proceedings are not automatically stayed by the filing of a petition for relief from judgment; a preliminary injunction is required to stay execution.