G.R. Nos. 226199 and 227242-54. October 01, 2018.
ROSITA TUASON MARAVILLA AND CORAZON TUASON MIRANDA, THROUGH THEIR ATTORNEY-IN-FACT, RUBENCITO M. DEL MUNDO, PETITIONERS, V. MARCELINO BUGARIN, ET AL., RESPONDENTS.

FACTS

Petitioners, owners of a parcel of land in San Andres, Manila, filed consolidated complaints for unlawful detainer against respondents, who were occupying portions of the land as lessees. The Metropolitan Trial Court (MeTC) ruled in favor of the petitioners, ordering respondents to vacate and pay rentals. This decision was affirmed in toto by the Regional Trial Court (RTC) of Manila, Branch 47, in a Consolidated Decision dated November 17, 2014. Petitioners moved for execution of this final judgment. Respondents opposed, citing supervening events, specifically that the City of Manila had passed ordinances to acquire the land and had subsequently filed an expropriation case (Civil Case No. 15-134874) over the same property.
The RTC initially granted execution but, upon respondents’ amended motion highlighting the filed expropriation case, issued the assailed Orders dated March 18, 2016 and July 28, 2016, suspending the issuance of the writ of execution. The RTC considered the filing of the expropriation case a supervening event that rendered execution inequitable. Meanwhile, the Court of Appeals denied respondents’ appeal of the ejectment judgment, and the RTC branch hearing the expropriation case rendered a decision declaring the City’s right to take the property and ordering payment of just compensation.

ISSUE

Whether the RTC erred in suspending the execution of its final decision in the ejectment cases on the ground of a supervening event, namely the filing of an expropriation case over the subject property.

RULING

Yes, the RTC erred. The Supreme Court granted the petition and set aside the assailed Orders, directing the immediate execution of the ejectment judgment. The legal logic is anchored on the nature of ejectment judgments and the requirements for a valid supervening event to stay execution. A judgment in an ejectment case is immediately executory. Its execution may only be suspended upon a showing of supervening events that have brought about a material change in the situation of the parties, making execution inequitable.
Here, the filing of the expropriation case did not constitute such a material change. For an expropriation proceeding to affect possession, the local government unit must, upon filing, make the required deposit (at least 15% of the fair market value) to be entitled to immediate possession. The records failed to show that the City of Manila had made this judicial deposit in favor of the petitioners. Without such deposit, the City did not acquire a superior right of possession that could supersede the petitioners’ right, as confirmed by the final ejectment judgment, to recover physical possession. The expropriation case merely established the City’s right to acquire ownership eventually, but did not automatically transfer possession, especially since the just compensation had not yet been fully paid to the landowners. Consequently, the respondents’ possession remained unlawful under the final ejectment ruling. The suspension of execution was therefore unwarranted.