G.R. No. 75206 September 5, 1989
Tomas Galgala and Francisca L. Galgala (substituted by Helen Rose G. Cadelina and Esther G. Ymana), petitioners, vs. Benguet Consolidated, Inc., Conrado H. Bueno, the Regional Trial Court of Baguio, Branch IV, the City Sheriff of Baguio City and the Intermediate Appellate Court, respondents.

FACTS

The late spouses Tomas and Francisca Galgala executed a Memorandum of Agreement and three deeds of sale on May 19, 1977, conveying three parcels of land to respondent Benguet Consolidated, Inc. (BCI) to settle a cash shortage allegedly incurred by Francisca during her employment. Titles were transferred to BCI. The Galgalas remained on the property, initially by request and later as lessees. For failure to pay rentals, BCI filed an unlawful detainer case (Civil Case No. 6766) in 1979. The Municipal Trial Court rendered a decision in favor of BCI on November 26, 1983, ordering the Galgalas to vacate and pay compensation. No appeal was taken, making the judgment final and executory.
Meanwhile, on September 20, 1979, the Galgala spouses filed a separate action (Civil Case No. 3656) before the Regional Trial Court for annulment of the Memorandum of Agreement and deeds of sale, alleging vitiation of consent by force, duress, and fear, and praying for reconveyance of the same properties. After a writ of execution was issued in the ejectment case, the Galgalas (and later their heirs) filed a petition for preliminary injunction in Civil Case No. 3656 to stop the enforcement of the ejectment judgment. The RTC denied the petition. The Intermediate Appellate Court affirmed the denial, prompting this petition.

ISSUE

Whether the execution of the final and executory judgment in the ejectment case may be stayed by the pendency of an action for annulment of documents and reconveyance involving the same property.

RULING

No. The Supreme Court denied the petition, ruling that the execution of a final judgment in an ejectment case cannot be stayed by the pendency of an action for annulment of documents and damages. The legal logic is anchored on the distinct nature and subject matter of the two proceedings. An unlawful detainer action, governed by Rule 70 of the Rules of Court, deals solely with the issue of material possession or possession de facto. The judgment therein is conclusive only with respect to possession and does not bind title or affect ownership. Conversely, an action for annulment and reconveyance primarily involves the issue of ownership.
The Court emphasized that the two cases are independent of each other. The finality of the ejectment judgment vested BCI with a clear legal right to possession, which must be enforced without delay. The pendency of the annulment suit merely creates an expectancy of a favorable outcome for the petitioners, which cannot override an existing right enforceable by a final judgment. To hold otherwise would undermine the summary nature of ejectment proceedings, which are designed to provide a speedy remedy for the recovery of possession. The protracted ten-year litigation of the detainer case already constituted an undue delay contrary to the objectives of summary procedure. The Court reiterated its vigilance against dilatory tactics that frustrate the execution of final judgments.