G.R. No. 145284 February 11, 2004
ROSITA DAVID, petitioner, vs. SPOUSES ROD and CYNTHIA NAVARRO, and THE COURT OF APPEALS, respondents.

FACTS

Andrew David died intestate, survived by his wife Teodora and mother Rosita David (petitioner). An estate settlement proceeding (Sp. Proc. No. 10436) was initiated. The probate court authorized Teodora and Rosita to sell estate properties, including a Quezon City lot. Teodora, without Rosita’s conformity, executed a Deed of Conditional Sale over the lot to spouses Rod and Cynthia Navarro (respondents), who paid a P1M downpayment and took possession. Rosita filed an affidavit of adverse claim on the title and subsequently secured a judgment from the RTC in Civil Case No. Q-95-23351 annulling the deed of sale as void for lack of probate court approval and Rosita’s conformity. While the Navarro spouses appealed this annulment (CA-G.R. CV No. 59872), Rosita, appointed as administratrix of the estate, filed an unlawful detainer case against them to recover possession of the lot. The MeTC ruled for Rosita, a decision affirmed by the RTC.

ISSUE

Whether the Court of Appeals acted with grave abuse of discretion in issuing a writ of preliminary injunction that enjoined the execution of the final and executory judgment in the unlawful detainer case.

RULING

The Supreme Court denied the petition. The core legal principle is the immediate executory nature of judgments in ejectment cases under Section 21, Rule 70 of the Rules of Court. This rule is designed to prioritize the restoration of physical possession. A judgment in favor of the plaintiff in unlawful detainer becomes immediately executory upon motion once the RTC renders its decision on appeal. The only way for a losing defendant to stay execution is to: (1) perfect an appeal; (2) file a sufficient supersedeas bond; and (3) periodically deposit the accruing rentals during the appeal’s pendency. In this case, the Navarro spouses, as defendants in the ejectment suit, failed to file the required supersedeas bond and make the periodic rental deposits to the appellate court. Consequently, the RTC’s affirmance of the MeTC’s ejectment judgment became immediately final and executory. The Court of Appeals’ issuance of a preliminary injunction to enjoin this execution was a grave abuse of discretion, as it contravened the mandatory and immediate executory nature of ejectment judgments. The Supreme Court, however, noted that the issue was mooted by subsequent events, as the Navarro spouses had already voluntarily vacated the property, rendering the injunction inoperative.