GR 78827; (April, 1989) (Digest)
G.R. No. 78827 April 17, 1989
ENRIQUE L. S. VILLARUEL, et al., petitioners, vs. HON. COURT OF APPEALS, LOLITA LOPEZ and MAGNO DE LA TORRE, respondents.
FACTS
The petitioners, the Villaruel family, owned three commercial lots in Bacolod City which they leased to the respondents, the Lopezes, under a 1955 contract for ten years, extendible for another ten years subject to a new agreement on rental rates. The original lease expired in 1965. After the Villaruels requested a new rental rate, the Lopezes paid three months’ rent under a temporary receipt, which the Villaruels accepted subject to further negotiation. The Lopezes claimed this payment constituted an implied extension of the lease. The Villaruels disagreed and filed an unlawful detainer suit. The Municipal Court ruled for the Villaruels, a decision affirmed by the Court of First Instance (CFI) of Negros Occidental on July 12, 1968, ordering the Lopezes to vacate the lots and pay accrued rentals.
The Lopezes engaged in protracted litigation to resist execution. They appealed to the Court of Appeals, which eventually dismissed their appeal on the merits in 1972, making the CFI judgment final. Despite this finality, the Lopezes filed multiple petitions and motions, including to this Court, to obstruct the issuance and implementation of writs of execution. An alias writ was finally issued by the Regional Trial Court (RTC) in 1986, and possession was delivered to the Villaruels on October 6, 1986, with the building on the property demolished that December. Nevertheless, the Lopezes filed another “Urgent Motion to Nullify” the execution, which the RTC denied. The Court of Appeals, however, granted the Lopezes’ subsequent petition for certiorari on May 22, 1987, annulling the RTC’s execution orders and directing a hearing on who should be ejected. The Villaruels elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals gravely abused its discretion in annulling the execution of the final and executory 1968 CFI judgment and in ordering a new hearing on the matter of possession.
RULING
Yes, the Court of Appeals committed grave abuse of discretion. The Supreme Court reversed its decision. The core legal principle is that a final and executory judgment must be executed as a matter of right, and its execution cannot be impeded by new issues or collateral attacks. The CFI decision of July 12, 1968, which ordered the Lopezes to vacate the specific lots, became final in 1972. All subsequent proceedings were merely for the enforcement of this immutable judgment.
The appellate court’s order for a new hearing to determine who should be ejected was a patent error. The CFI judgment clearly ordered the defendants Lopezes to vacate the lots. The possession of the building (Floredith Theater) was inseparable from the possession of the land it stood on, which was the very subject of the ejectment suit. The Lopezes’ sublessees in the building derived their possessory right from the Lopezes; thus, ejecting the Lopezes necessarily included ejecting all those claiming possession under them. The execution in 1986 was a mere continuation of the lawful 1971 execution that had been upheld by this Court. By the time the Court of Appeals issued its 1987 decision, execution had already been fully implemented in 1986, rendering the case moot. The Supreme Court condemned the Lopezes’ two-decade strategy of using procedural maneuvers to frustrate a final judgment, which constituted a gross abuse of the judicial process to the
