GR 120132; (December, 1995) (Digest)
G.R. No. 120132. December 4, 1995. CRISANTA GALAY, ET AL., petitioners, vs. COURT OF APPEALS and VIRGINIA WONG, represented by her Administrator, ATTY. REYNALDO B. HERNANDEZ, respondents.
FACTS
Private respondent Virginia Wong, through her administrator, filed an ejectment suit against petitioners Crisanta Galay, et al., for illegally occupying her titled lot in Quezon City. Petitioners, while not claiming ownership, asserted possession since 1972 by tolerance of a Dr. Alejo Lopez. The Metropolitan Trial Court ordered their ejectment, a decision affirmed by the Regional Trial Court. The Court of Appeals dismissed petitioners’ subsequent petition for review on procedural grounds, rendering the judgment final. Private respondent then secured an alias writ of execution.
To prevent execution, petitioners filed an injunction case before the RTC, arguing that their eviction required prior compliance with Section 28(c) of Republic Act No. 7279 (Urban Development and Housing Act of 1992), which mandates relocation and financial assistance for qualified urban poor. The RTC denied injunctive relief. Petitioners elevated the matter to the Court of Appeals via certiorari, which initially granted a preliminary injunction. After hearings, the appellate court rendered a decision ordering the People’s Bureau to relocate petitioners by a specific date, after which they must vacate, with provisions for a daily allowance for any delay.
ISSUE
Whether the final and executory judgment in the ejectment case can be suspended or set aside for non-compliance with the relocation and financial assistance requirements under R.A. No. 7279.
RULING
No. The Supreme Court denied the petition. The legal logic is anchored on the hierarchy of rights and the finality of judgments. The Court held that while R.A. No. 7279 provides social justice mechanisms, its provisions cannot be invoked to nullify or indefinitely stay a final and executory judgment. A final judgment in an ejectment case conclusively establishes the lawful owner’s right to possession and the occupant’s lack of a valid claim. The requirements of R.A. No. 7279, such as notice, relocation, and financial assistance, are intended to be implemented in the execution phase of such a final judgment to ensure an orderly and humane process. They are not legal prerequisites that retroactively invalidate the judgment itself or provide a new cause of action to re-litigate possession.
The Court emphasized that social justice cannot be used to perpetuate an illegal act or deprive a lawful owner of property. The law does not countenance wrongdoing by the underprivileged. The policy aims to mitigate the harsh effects of eviction through proper relocation, not to arm squatters with a legal shield to indefinitely resist a final court order. Therefore, petitioners’ obligation to vacate, as decreed by the final judgment, remains enforceable, with the implementing agencies tasked to carry out the relocation concurrently with or following the execution, as directed by the Court of Appeals.