GR 183858; (April, 2013) (Digest)
G.R. No. 183858; April 17, 2013
HOLY TRINITY REALTY DEVELOPMENT CORPORATION, represented by JENNIFER R. MARQUEZ, Petitioner, vs. SPOUSES CARLOS AND ELIZABETH ABACAN, Respondents.
FACTS
Petitioner Holy Trinity Realty Development Corporation (HTRDC) acquired a parcel of land in Malolos City registered under TCT No. 103697 from Freddie Santiago on August 23, 1999. Upon acquisition, HTRDC found the land occupied by respondents Spouses Carlos and Elizabeth Abacan and others. HTRDC initially filed a forcible entry complaint but withdrew it to verify claims that the land was covered by emancipation patents from the DARAB. HTRDC then filed a DARAB case for cancellation of emancipation patents, which was granted by the provincial adjudicator on April 30, 2002, and later affirmed by the DARAB. On November 4, 2003, HTRDC filed an unlawful detainer complaint with the MTCC of Malolos against the occupants, including respondents, alleging that after its demands to vacate were ignored, it needed to resort to ejectment. The MTCC ruled in favor of HTRDC, ordering the occupants to vacate and pay rent, attorney’s fees, and costs. Respondents’ motion for reconsideration was denied as a prohibited pleading, and their appeal was denied for being filed out of time, making the MTCC Decision final and executory. The MTCC issued a writ of execution. Respondents filed multiple actions in the RTC (for annulment of judgment, certiorari, and quieting of title), all of which were dismissed on grounds of forum shopping, immutability of judgment, and finality of judgment, with no appeals taken. The MTCC issued an Alias Writ of Execution and an Alias Special Order of Demolition. Respondents moved to quash these writs, arguing that Emancipation Patent Nos. 00780489 and 00780490 had been issued in their favor during the pendency of the case, constituting a supervening event that gave them ownership. The MTCC denied the motion, ruling that subsequent acquisition of ownership is not a supervening event barring execution in an unlawful detainer case. Respondents then filed a Special Civil Action for Certiorari directly with the CA, which granted the petition, recalled the MTCC Order, and granted the motion to quash, holding that the MTCC had no jurisdiction over the unlawful detainer case. HTRDC filed this Petition for Review.
ISSUE
1. Whether respondents erred procedurally by filing a petition for certiorari directly with the CA instead of the RTC.
2. Whether the CA committed reversible error in ruling that the MTCC had no jurisdiction over the unlawful detainer case.
3. Whether the MTCC committed grave abuse of discretion in denying respondents’ motion to quash the alias writs based on the alleged supervening event of their acquisition of emancipation patents.
RULING
1. On the procedural issue: Yes, respondents violated the principle of hierarchy of courts. While the Supreme Court, CA, and RTC have concurrent jurisdiction to issue writs of certiorari, petitions against first-level (inferior) courts like the MTCC should be filed with the RTC. Respondents’ direct filing with the CA was dismissible on procedural grounds.
2. On the CA’s ruling on jurisdiction: Yes, the CA committed reversible error. The petition for certiorari before the CA was directed at the MTCC’s Order denying the motion to quash, not at the MTCC’s Consolidated Decision in the unlawful detainer case, which had long become final and immutable due to respondents’ failure to timely appeal. The CA’s review should have been limited to whether the MTCC committed grave abuse of discretion in denying the motion to quash, not to re-examining the MTCC’s jurisdiction over the original ejectment case.
3. On the denial of the motion to quash: No, the MTCC did not commit grave abuse of discretion. The sole ground for the motion was the alleged supervening event of respondents acquiring ownership through emancipation patents after the judgment. The MTCC correctly applied Supreme Court precedents (Oblea v. Court of Appeals and Chua v. Court of Appeals) holding that subsequent acquisition of ownership is not a supervening event that bars execution of a judgment in an unlawful detainer case, as the sole issue in such a case is physical or material possession, which had already been adjudicated. The MTCC’s denial was not capricious, whimsical, or arbitrary; hence, no grave abuse of discretion existed.
The Supreme Court granted HTRDC’s petition, reversing the CA Decision and Resolution, and reinstated the MTCC Order denying the motion to quash the alias writs.