G.R. No. L-32642 November 26, 1973
DOMINADOR STA. ANA, petitioner, vs. HON. DELFIN VIR. SUNGA, Judge of the Court of First Instance of Camarines Sur, Branch I, MAURO B. FAJARDO, Provincial Sheriff of Camarines Sur, PELICULA SABIDO and MAXIMO RANCES, respondents.

FACTS

In a quieting of title case, respondents Pelicula Sabido and Maximo Rances were declared the owners of a parcel of land designated as Lot B and were awarded possession against the plaintiffs, Victor Dasal and Maria Pecunio. After the judgment became final, a writ of execution was issued. The sheriff’s return indicated that material possession was delivered to the respondents, except for a specific western portion enclosed by a concrete wall, which was claimed by petitioner Dominador Sta. Ana, who was not a party to the case. Respondents then filed a motion to eject Sta. Ana and to demolish structures on the lot, alleging he was a transferee of the defeated plaintiffs acting in bad faith to frustrate the judgment.
Petitioner Sta. Ana filed an answer, asserting he was a stranger to the case and therefore not bound by the judgment. He claimed ownership of a larger parcel, part of which included the disputed area, by virtue of an absolute sale from a different vendor in 1951. He demanded a hearing to prove his independent title and possession. The respondent court, however, issued an order directing Sta. Ana and others to demolish their houses on the lot, effectively enforcing the judgment against him without conducting a hearing on his claims.

ISSUE

Whether the respondent court acted without or in excess of jurisdiction or with grave abuse of discretion in issuing a demolition order against petitioner, who was not a party to the original case, without first conducting a hearing to determine the validity of his claim of ownership and possession.

RULING

Yes. The Supreme Court granted the writs of certiorari and prohibition, setting aside the questioned orders. The Court emphasized that a judgment in personam is binding only upon the parties to the action and their privies. Since petitioner Sta. Ana was not a party to the case, and no relation of privity with the losing plaintiffs had been established, the judgment could not be enforced against him summarily. The respondent court’s denial of a hearing deprived petitioner of his right to due process. The proper procedure was to conduct a hearing to receive evidence on whether petitioner was a privy or a transferee pendente lite of the defeated parties, or whether he was a possessor in good faith with an independent claim of title. The case was remanded to the court of origin for this purpose. The Court held that a property right cannot be taken without affording the claimant an opportunity to be heard.