G.R. No. L-23702 January 30, 1968
MARIA VILLAFLOR, petitioner, vs. ARTURO REYES, HON. FIDEL FERNANDEZ, in his capacity as Judge of the Court of First Instance of Samar and THE PROVINCIAL SHERIFF OF SAMAR, respondents.

FACTS

1. Petitioner Maria Villaflor was a tenant of the late Ramona Reyes on a foreshore land in Catbalogan, Samar, under a verbal month-to-month lease at P50.00 rental.
2. Ramona Reyes instituted an ejectment proceeding (Civil Case No. 4694) against Villaflor and the Samar Cooperative Store (SACOS) after a fire in 1957, demanding they vacate the land so she could construct her own building. The Justice of the Peace Court and the Court of First Instance of Samar decided in favor of Reyes, declaring her the lawful possessor and ordering Villaflor to vacate.
3. Villaflor appealed to the Supreme Court (G.R. No. L-15755), which affirmed the lower court’s decision on May 30, 1961. The Supreme Court, through Chief Justice Bengzon, held that as a tenant, Villaflor was barred by a conclusive presumption from denying her landlord’s (Reyes’) title at the commencement of their landlord-tenant relationship.
4. Subsequently, Villaflor filed an application with the Bureau of Lands for the same foreshore land. The Secretary of Agriculture and Natural Resources, in a decision dated March 29, 1961, ordered that the land be opened to public bidding, clarifying that Ramona Reyes’ permit had been cancelled in 1944, Villaflor’s application was in excess of what was allowed by law, and none of the litigants had preferential rights.
5. After the Supreme Court decision became final, respondent Judge Fidel Fernandez issued an order dated August 17, 1964, for the execution of the ejectment judgment, directing the Provincial Sheriff to demolish Villaflor’s constructions and deliver the land to the plaintiff (the heir, Arturo Reyes, as Ramona Reyes had died on June 18, 1960).
6. Villaflor filed this original petition for certiorari on October 23, 1964, seeking to enjoin the enforcement of the demolition order. The Supreme Court initially dismissed the petition for lack of merit on October 27, 1964, but upon Villaflor’s motion for reconsideration (arguing execution was sought only after almost four years from the affirmance of the judgment), reconsidered and issued a preliminary injunction on November 12, 1964.
7. Respondents answered, stating that the Sheriff had already demolished Villaflor’s constructions and delivered possession to Arturo Reyes after the Court’s initial dismissal resolution but before the reconsideration, rendering the case moot. They also asserted that the Bureau of Lands, after initially enjoining construction, later allowed Arturo Reyes to proceed with building provided he secured the necessary permit.

ISSUE

Whether the respondent Judge committed a grave abuse of discretion amounting to lack of jurisdiction in issuing the order of execution (dated August 17, 1964) for the demolition of petitioner’s constructions and delivery of the land, despite the subsequent administrative decision of the Secretary of Agriculture and Natural Resources ordering the public bidding of the foreshore land and the death of the original plaintiff.

RULING

The Supreme Court DENIED the petition for certiorari.
1. Finality of the Ejectment Judgment: The ejectment judgment in Civil Case No. 4694, which was affirmed by the Supreme Court, had long become final and executory. The rule on conclusiveness of judgment applies. The issue of rightful possession as between Villaflor and Ramona Reyes (and her successor-in-interest, Arturo Reyes) was definitively settled by that final judgment. Villaflor, as a tenant, was conclusively presumed not to deny her landlord’s title at the start of their relationship.
2. Administrative Decision Does Not Nullify Judicial Decree: The subsequent decision of the Secretary of Agriculture and Natural Resources did not nullify the final judicial decree in the ejectment case. The administrative order pertained to the disposition of the foreshore land by the state and the cancellation of permits, but it did not overturn the judicial determination of possessory rights between the private parties. The Secretary’s decision explicitly placed all litigants on equal footing for the public bidding, granting no preferential right to Villaflor.
3. Death of Plaintiff and Delay in Execution: The death of the original plaintiff, Ramona Reyes, did not invalidate the judgment or the right to its execution. Her heir, Arturo Reyes, was a proper party to seek execution. The delay of almost four years in seeking execution did not constitute a waiver or abandonment of the right, especially since there was no allegation of a change in Villaflor’s possession that would give her a new right.
4. Mootness and Absence of Grave Abuse: The Court found that the demolition had already been carried out pursuant to the lawful order after the initial dismissal of the petition. Even if not moot, the respondent Judge’s order was a strict and full compliance with his duty to enforce a final judgment. Issuing a writ of execution for a final judgment is a ministerial duty, and the Judge did not commit any grave abuse of discretion. Public policy demands that litigation must end, and final judgments must be executed.
5. Policy Against Prolonging Litigation: The Court emphasized the importance of finality of judgments. Litigants should not be allowed to evade final and executory decisions through schemes that prolong controversy. The judiciary’s time should not be wasted on efforts to evade the operation of a final decision, particularly where, as here, the petitioner’s lack of any vindicable right was obvious.
WHEREFORE, the petition for certiorari was denied. Costs against petitioner Villaflor.