G.R. No. L-40437 September 27, 1977
LOURDES GUARDACASA VDA. DE LEGASPI, petitioner, vs. HON. HERMINIO A. AVENDAÑO, as Presiding Judge of Biñan Br. I of the Court of First Instance of Laguna, HON. WENCESLAO E. HERCE, as Municipal Judge of San Pedro, Laguna, ROGELIO S. MOLINA, as Deputy Provincial Sheriff of Laguna and JOSE O. LEGASPI, respondents.

FACTS

Private respondent Jose O. Legaspi filed an ejectment case (Civil Case No. 953) against petitioner Lourdes Guardacasa Vda. de Legaspi in the Municipal Court of San Pedro, Laguna, concerning a residential lot. Petitioner moved to dismiss, asserting the municipal court lacked jurisdiction as ownership was in dispute. The motion was denied, petitioner was declared in default, and judgment was rendered against her. This judgment became final, leading to a writ of execution and an order of demolition. Subsequently, petitioner filed an action for quieting of title (Civil Case No. 929) in the Court of First Instance of Laguna (CFI), praying for a preliminary injunction to suspend the demolition. The CFI initially dismissed this petition. Meanwhile, a related certiorari case (CA-G.R. No. 01551) reached the Court of Appeals, which enjoined the CFI from proceeding with a separate certiorari case (Civil Case No. 927) but did not explicitly address the quieting of title case. Petitioner sought relief from the Supreme Court, which denied her petition but explicitly stated it was “without prejudice to petitioners’ seeking injunction in Civil Case No. B-929 for quieting of title.”

ISSUE

Whether the Court of First Instance, in an action for quieting of title where ownership is directly involved, can and should issue a preliminary injunction to suspend execution of a final ejectment judgment from an inferior court.

RULING

Yes. The Supreme Court granted the petition, nullifying the CFI’s orders of dismissal and directing the suspension of the ejectment proceedings. The legal logic is anchored on the hierarchy of courts and the substantive nature of the pending action. An ejectment case in an inferior court primarily determines physical possession (possession de facto) and cannot conclusively resolve questions of ownership. In contrast, an action for quieting of title in the CFI directly adjudicates ownership, which is a superior and substantial right encompassing the right to possession. When such a plenary action is pending, it is legal error for the CFI to refuse to exercise its equity jurisdiction to issue injunctive relief. The Court clarified that its prior resolution was a directive for the CFI to hear and resolve the injunction plea on its merits, considering the circumstances, and not to be bound by the inferior court’s ejectment ruling. The proper procedure is for the CFI to hear the injunction motion and, if warranted, order the suspension of the ejectment case’s execution, with any accruing rentals or income from the property to be deposited with the inferior court pending the final outcome of the ownership dispute. This ensures that the execution of a merely possessory judgment does not preempt or render nugatory a final determination on the more fundamental issue of title. Consequently, the CFI was ordered to proceed with Civil Case No. 929, and the municipal judge and sheriff were enjoined from enforcing the writ of execution and demolition order until the title case is finally terminated.