G.R. No. 145254 ; July 20, 2006
Knecht, Incorporated, as trustee for the stockholders and creditors of Rose Packing Co., Inc., petitioner, vs. Municipality of Cainta and Encarnacion Gonzales-Wong, respondents.

FACTS

This petition for review stemmed from multiple lower court proceedings involving a parcel of land originally owned by Rose Packing Co., Inc. In 1965, Rose Packing sold the land to United Cigarette Corporation (UCC), but a dispute arose, leading to Civil Case No. 9165 for specific performance. A 1969 decision favored UCC, but execution was hindered when a mortgagee bank foreclosed on the property. Ultimately, the Supreme Court invalidated that foreclosure, revesting title in Rose Packing. Subsequently, UCC moved for execution of the 1969 judgment, and the RTC-Pasig issued an alias writ of execution on March 24, 1994.
Simultaneously, the Municipality of Cainta initiated expropriation proceedings (Civil Case No. 90-1817) against the same property. The RTC-Antipolo issued orders in 1992, including a condemnation order and a writ of possession for the municipality, and excluded Rose Packing as a party-defendant upon UCC’s motion. Later, Knecht, Inc., as Rose Packing’s successor, filed a petition (LRC Case No. 96-1743) to cancel encumbrances on the title, which was dismissed. Knecht, Inc. then filed a petition for annulment of judgment with the Court of Appeals, challenging the various orders from the three proceedings, but the CA denied it.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the assailed orders of the trial courts, particularly concerning the execution of the 1969 judgment in favor of UCC and the orders in the expropriation case that excluded Rose Packing and granted possession to the Municipality of Cainta.

RULING

The Supreme Court denied the petition and affirmed the CA decision. On the execution of the 1969 judgment, the Court held that the final and executory decision in Civil Case No. 9165 conclusively established UCC’s right to the property. The subsequent invalidation of the bank’s foreclosure removed the impediment to execution, and UCC’s motion for an alias writ was proper. The dissolution of UCC did not extinguish the judgment debt, as its corporate existence continues for three years for liquidation purposes, during which it can prosecute and defend suits.
Regarding the expropriation orders, the Court found no grave abuse of discretion. The trial court correctly issued the writ of possession upon the municipality’s deposit, as compliance with the requirements of the applicable law (RA 8974) entitles the government to immediate possession. The exclusion of Rose Packing as a party was justified because, under the final 1969 judgment, any interest Rose Packing had in the property was deemed transferred to UCC. Therefore, Rose Packing no longer had a legal interest to protect in the expropriation case. The Court found the petition to be a dilatory tactic, noting that the petitioner had engaged in multiple suits revolving around the same property and issues already settled by final judgment.