GR 117389; (May, 1995) (Digest)
G.R. No. 117389 May 11, 1995
Romeo V. Oblea and Ramon S. Melencio, petitioners, vs. Court of Appeals and Juan S. Esteban, respondents.
FACTS
The dispute involves a lot in Cabanatuan City. Private respondent Juan Esteban filed an ejectment suit against petitioner Romeo Oblea in the Municipal Trial Court (MTC). The MTC ruled in favor of Esteban, ordering Oblea to vacate. This decision was affirmed with modification by the Regional Trial Court (RTC) and later by the Court of Appeals, becoming final and executory. During the pendency of the ejectment proceedings, the registered owners of the lot sold it to petitioner Oblea. Oblea and his co-owners then filed a separate action for quieting of title against Esteban in the RTC, challenging the validity of his title. Upon motion for execution of the final ejectment judgment, petitioners filed a petition for certiorari and prohibition in the RTC to stop it, securing a temporary restraining order. This TRO was later lifted by the RTC, prompting petitioners to appeal to the Court of Appeals.
ISSUE
Whether the subsequent sale of the disputed property to petitioner Oblea, and the pending action for quieting of title, constitute a supervening event that bars the execution of the final and executory judgment in the ejectment case.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. The Court held that the argument based on a “supervening event” was untenable. The sole issue in an unlawful detainer case is physical or material possession (possession de facto), not ownership (possession de jure). The finality of the ejectment judgment, which found Esteban to have a better right of possession, rendered its execution a matter of right. The subsequent acquisition of ownership by Oblea during the appeal and the institution of a quieting of title action do not affect the enforceability of the ejectment decree. These are matters pertaining to ownership, which are separate from and do not divest the MTC of its jurisdiction over the already-concluded possessory action. The Court found the petitioners’ various actions to be merely dilatory tactics designed to delay the execution of a long-settled issue.