Soco v. CA
G.R. No. 116013 (October 21, 1996)
Facts:
The case originated from a civil ejectment action filed by Clemente L. Santiago against Ananias and Filemon Soco in the Municipal Trial Court (MTC) of Malolos, Bulacan, on February 7, 1983. After a lengthy legal battle spanning over thirteen years, the MTC rendered a judgment in favor of Santiago on January 21, 1991. The Socos appealed this decision to the Regional Trial Court (RTC) of Malolos, which affirmed the MTC's ruling on May 9, 1991. The Socos' motion for reconsideration was denied on August 21, 1991, and the RTC's decision became final and executory due to the Socos' failure to file a petition for review with the Court of Appeals, despite having been granted an extension to do so.
Subsequently, Santiago filed a motion for the issuance of a writ of demolition against the Socos, which led to an order from the MTC on May 19, 1993, giving the Socos seven days to vacate the premises. When the Socos did not comply, a writ of demolition was issued on June 2, 1993. To prevent the enforcement of this writ, the Socos filed a petition for certiorari and injunction with the RTC, which was dismissed on July 20, 1993. Their motion for reconsideration was also denied on September 8, 1993.
The Socos then appealed to the Court of Appeals, arguing that new facts had emerged that would render the execution of the MTC's decision unjust. They cited a favorable decision in a separate case (Civil Case No. 562-M-90) involving the estate of the late Basilio Santiago, which purportedly awarded them rights to the land in question.
Issues:
The primary legal issue presented was whether the MTC could be prevented from issuing a writ of execution and demolition in the ejectment case due to the existence of a serious question of ownership and a favorable decision in a related case.
Arguments:
The Socos contended that the RTC's decision in Civil Case No. 562-M-90, which favored them regarding the land they occupied, constituted a new fact that justified the non-enforcement of the final and executory judgment in the ejectment case. They argued that this new development should have been considered by the Court of Appeals in their petition.
Conversely, Santiago and the Court of Appeals maintained that the Socos had not demonstrated any reversible error. They argued that the decision in the ejectment case had already become final and executory, and that the existence of a separate case regarding ownership did not affect the MTC's jurisdiction to decide on matters of possession. They emphasized that the ejectment case was solely concerned with material possession, not ownership.
Court's Decision and Legal Reasoning:
The Court upheld the decision of the Court of Appeals, stating that the Socos had failed to show that any reversible error was committed. The Court noted that the Socos had availed themselves of the wrong mode of appeal by filing a petition for review instead of a notice of appeal regarding the RTC's dismissal of their certiorari petition.
The Court reiterated the principle that once a judgment becomes final and executory, it is the ministerial duty of the trial court to issue a writ of execution. However, it acknowledged that execution could be refused on equitable grounds if new facts or circumstances arose after the judgment that would render execution unjust. The Court found that the facts cited by the Socos were not new, as the related case had been pending before the RTC prior to the MTC's judgment in the ejectment case.
The Court also referenced established jurisprudence, asserting that the pendency of an action questioning ownership does not abate ejectment suits or bar the execution of judgments therein, as the issues of possession and ownership are distinct.
Significant Legal Principles Established:
Finality of Judgment: Once a judgment becomes final and executory, it is the duty of the court to enforce it through a writ of execution, barring any new facts that would render such enforcement unjust.
Distinction Between Possession and Ownership: Ejectment cases focus solely on material possession, and the existence of a separate action regarding ownership does not affect the jurisdiction of the court to resolve possession issues.
Equitable Grounds for Non-Enforcement: New facts or circumstances that arise after a judgment has become final may justify the non-enforcement of that judgment, but such facts must be genuinely new and not merely related to ongoing litigation.