G.R. No. L-49823 February 26, 1992
THE HEIRS OF EUGENIO SEVILLA, INC., petitioner, vs. THE COURT OF APPEALS and CORAZON BABAO-GONZALES, respondents.

FACTS

Petitioner Heirs of Eugenio Sevilla, Inc. filed an unlawful detainer case against Jesus Co before the City Court of Manila, alleging Co failed to pay rentals for a theater building. Co claimed ownership via a deed of sale and counter-alleged he had leased the property to private respondent Corazon Babao-Gonzales. The City Court ruled in favor of the petitioner, declared the deed of sale a forgery, and ordered Co and all persons claiming under him to vacate. Co did not appeal, making the judgment final. A writ of execution was issued, and the sheriff ejected the occupants, padlocked the premises, and delivered possession to the petitioner.
Subsequently, respondent Gonzales, claiming to be Co’s lessee, filed a petition for declaratory relief and injunction in the Court of First Instance (CFI) to challenge the execution. After the sheriff had already delivered possession, Gonzales forcibly re-entered the premises. The CFI denied her petition and lifted a restraining order, finding she was a mere wrongdoer interfering with a legally executed judgment. However, the Court of Appeals reversed the CFI, ordering Gonzales’s restoration to possession upon posting a bond.

ISSUE

Whether a sublessee, not a party to the ejectment case, can resist execution of a final judgment against the lessor.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the CFI order. The legal logic is anchored on the principle of privity and the derivative nature of a sublessee’s rights. A judgment in an ejectment case is binding not only on the parties but also on their privies, including sublessees claiming rights under the defeated party. Since Jesus Co’s right to possess was conclusively extinguished by the final judgment, his sublessee, Corazon Babao-Gonzales, could assert no better right. Her possession was entirely dependent on Co’s, which was lawfully terminated.
The Court emphasized that a sublessee’s right is subordinate to the lessor’s. Once the lessee is duly ousted, the sublessee has no independent leg to stand on and cannot obstruct the execution. Gonzales’s remedy, if any, was to seek damages from her sublessor, Co, not to interfere with the sheriff’s enforcement of a final judgment. Her forcible re-entry after the sheriff had delivered possession constituted unlawful disturbance of the petitioner’s acquired possession. Therefore, the execution was valid and binding upon her.