G.R. No. 75206 September 5, 1989
Tomas Galgala and Francisca L. Galgala (substituted by Helen Rose G. Cadelina and Esther G. Ymana), petitioners, vs. Benguet Consolidated, Inc., Conrado H. Bueno, The Regional Trial Court of Baguio, Branch IV, the City Sheriff of Baguio City and the Intermediate Appellate Court, respondents.

FACTS

The late spouses Tomas and Francisca Galgala executed a Memorandum of Agreement and three deeds of sale on May 19, 1977, conveying three parcels of land to respondent Benguet Consolidated, Inc. (BCI) to settle a cash shortage allegedly incurred by Francisca during her employment. BCI redeemed the lots, secured titles in its name, and initially allowed the spouses to remain on the property, later accepting them as lessees. Due to the spouses’ failure to pay rentals, BCI filed an unlawful detainer case (Civil Case No. 6766) in 1979. The Municipal Trial Court rendered a decision in favor of BCI on November 26, 1983, ordering the spouses to vacate and pay compensation. This decision became final and executory.
Meanwhile, on September 20, 1979, the spouses filed a separate action (Civil Case No. 3656) before the Regional Trial Court for annulment of the Memorandum of Agreement and deeds of sale, alleging vitiation of consent by force, duress, and fear, and praying for reconveyance of the same properties. After a writ of execution was issued in the ejectment case, the petitioners (substituting the deceased spouses) filed a petition for preliminary injunction in Civil Case No. 3656 to enjoin the execution, arguing that the ejectment judgment should await the outcome of the annulment case. The RTC denied the injunction, a decision affirmed by the Intermediate Appellate Court.

ISSUE

Whether the execution of the final and executory judgment in the unlawful detainer case may be stayed by the pendency of a separate action for annulment of documents and reconveyance involving the same property.

RULING

No, the execution cannot be stayed. The Supreme Court denied the petition, emphasizing the distinct and independent nature of ejectment and annulment actions. Under Section 7, Rule 70 of the Rules of Court, a judgment in an unlawful detainer case is conclusive only on the issue of possession de facto and does not bind title or ownership. An ejectment suit concerns mere material possession, while an annulment or reconveyance action involves the issue of ownership. Therefore, the pendency of an annulment case does not constitute a prejudicial question that would justify staying the execution of a final ejectment judgment.
The Court highlighted the summary nature of ejectment proceedings, designed to provide a swift remedy for the restoration of possession. The ejectment case had already been protracted for ten years, and its final judgment had been rendered nearly six years prior. To delay execution further based on the separate annulment suit, which had not even been set for hearing as of 1987, would defeat the purpose of summary procedure and cause injustice to the prevailing party, BCI, which holds a clear, existing right to possession as the registered titleholder. The Court reaffirmed its vigilance against dilatory tactics that frustrate the implementation of final judgments.