G.R. No. 157866; February 14, 2007
AUGUSTO MANGAHAS and MARILOU VERDEJO, petitioners, vs. Hon. JUDGE VICTORIA ISABEL PAREDES, Presiding Judge, Br. 124, Regional Trial Court, Caloocan City; SHERIFF ERLITO BACHO, Br. 124, Regional Trial Court, Caloocan City; and AVELINO BANAAG, Respondents.

FACTS

Private respondent Avelino Banaag, the registered owner of a lot in Caloocan City, filed an ejectment suit against petitioners Augusto Mangahas and Marilou Verdejo before the Metropolitan Trial Court (MeTC). Petitioners claimed possession based on a Certificate of Occupancy from Pinagkamaligan Indo-Agro Development Corporation (PIADECO) and argued the MeTC lacked jurisdiction, asserting possession since 1978. They also moved to suspend proceedings, citing a Writ of Preliminary Injunction issued by the Quezon City RTC in a separate case involving the Tala Estate, which they claimed enjoined evictions in Caloocan City. The MeTC denied the motion, ruled for Banaag based on his Torrens title, and ordered petitioners to vacate. The RTC and Court of Appeals affirmed the decision. After the decision became final, petitioners filed a Motion to Suspend Execution before the RTC, again invoking the Quezon City injunction, which the RTC denied.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in denying the Motion to Suspend Execution based on a Writ of Preliminary Injunction issued by another RTC.

RULING

No, the RTC did not commit grave abuse of discretion. The Supreme Court affirmed the denial of the motion to suspend execution. The legal logic is anchored on the finality of judgments and the territorial jurisdiction of courts. The ejectment case had already been adjudicated with finality from the MeTC up to the Court of Appeals, establishing Banaag’s superior right of possession based on his Torrens title. A writ of execution of a final judgment is a ministerial duty. Petitioners’ reliance on the Quezon City RTC’s injunction was misplaced. The injunction, issued in a different case, binds only courts within the territorial jurisdiction of the issuing Quezon City RTC. It cannot nullify or impede the execution of a final and executory judgment rendered by a competent court in Caloocan City, as territorial jurisdiction is circumscribed by law. Furthermore, the attempt to re-litigate the injunction’s applicability, an issue previously resolved against petitioners in the appeal, is barred by conclusiveness of judgment. No exceptional circumstance was shown to warrant suspending execution, such as a supervening event rendering it unjust. Thus, the RTC correctly performed its ministerial duty to order execution.