GR 190043; (June, 2017) (Digest)
G.R. No. 190043, June 21, 2017
SANTOS-YLLANA REALTY CORPORATION, Petitioner vs. SPOUSES RICARDO DEANG and FLORENTINA DEANG, Respondents
FACTS
Respondent Florentina Deang, a lessee of a stall in petitioner’s shopping center, faced an ejectment complaint for unpaid rentals. The Metropolitan Trial Court (MTC) rendered a decision based on a compromise agreement. Upon her alleged failure to comply, petitioner moved for execution. The MTC granted the motion and issued a writ. Sheriff Pangan implemented the writ by padlocking the stall on June 5, 1998, turning over possession to petitioner.
Aggrieved, respondents filed a complaint for damages before the Regional Trial Court (RTC) of Manila. They alleged the writ’s implementation was illegal, causing them actual damages as business documents and funds were locked inside, halting operations and tarnishing goodwill. The RTC ruled in their favor, finding the execution unduly hasty and violative of due process, and held petitioner and the sheriffs jointly and severally liable for damages.
ISSUE
Whether petitioner Santos-Yllana Realty Corporation is solidarily liable with the sheriffs for damages arising from the implementation of the writ of execution.
RULING
No. The Supreme Court affirmed the Court of Appeals’ deletion of petitioner’s solidary liability. The legal logic rests on distinguishing the roles and liabilities of the winning party-litigant from the court officers tasked with implementing judicial orders. A writ of execution is addressed to the sheriff, not the party, and the manner of its enforcement is the sheriff’s official duty. The implementing officer is presumed to have performed his duties regularly and in accordance with law. For the party to be held liable for damages resulting from the execution, there must be proof of its direct participation, complicity, or specific instruction to perform the act in an illegal manner.
Here, petitioner was merely the successful plaintiff in the ejectment case who sought execution of a final judgment. There was no evidence that petitioner induced the sheriff to disregard procedural rules, such as the notice requirement under Rule 39. Absent any showing of malice, bad faith, or specific instruction from petitioner to implement the writ illegally, its liability cannot be sustained. The fault lay solely with the sheriff for failing to observe due process in the execution. Therefore, while the award of damages to respondents for the illegal closure was upheld, petitioner’s solidary liability was correctly removed.