G.R. No. L-14760; May 31, 1963
ANTONIO M. SAMIA, petitioner, vs. ROMAN REYES, MARIANO DE GULA, TITO ALDANA, MARIANO MANUEL, and THE COURT OF APPEALS, respondents.

FACTS

Petitioner Antonio M. Samia filed unlawful detainer cases against respondents in the Municipal Court of Manila. The respondents moved to suspend the proceedings under Republic Act No. 1599 . The Municipal Court granted a two-year suspension conditioned on respondents paying current rentals. Samia challenged this suspension via a petition for certiorari and mandamus in the Court of First Instance (CFI), which ruled the suspension erroneous and ordered the Municipal Court to proceed with the ejectment cases. Subsequently, the Municipal Court rendered judgments in favor of Samia, ordering respondents to vacate and pay rentals. Respondents appealed to the CFI but failed to file a supersedeas bond or pay current rentals as required by the Rules. The CFI thus issued orders for execution of the judgments. Meanwhile, the Land Tenure Administration initiated expropriation proceedings over the Samia estate. The Court of Appeals later set aside the CFI’s orders of execution, citing the pendency of the expropriation case.

ISSUE

Whether the Court of Appeals erred in setting aside the writs of execution issued by the CFI in the ejectment cases.

RULING

Yes. The Supreme Court reversed the Court of Appeals and reinstated the writs of execution. The legal logic is clear and multi-faceted. First, the suspension of ejectment proceedings under Republic Act No. 1162 , as amended, is a conditional privilege extended only to defendants who pay their current rentals. Respondents failed to comply with this condition, thereby forfeiting any statutory protection. Second, under the Rules of Court (Rule 72), a judgment in an ejectment case is immediately executory. The only exceptions to stay execution are: (1) perfecting an appeal and filing a supersedeas bond, and (2) during the appeal, paying current rentals to the plaintiff or depositing them in court. Respondents complied with neither prerequisite. The CFI therefore had a ministerial duty to order execution. Third, the pendency of expropriation proceedings does not automatically suspend ejectment cases, especially when the estate was later declared not to be a landed estate subject to such expropriation. Finally, the CFI’s orders for execution had attained finality and were beyond the appellate authority of the Court of Appeals to nullify. The respondents’ failure to avail of the statutory and procedural safeguards mandated the execution of the ejectment judgments.