GR L 3489; (September, 1907) (Digest)
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FACTS
Vicente Navales filed a complaint seeking 1,200 Philippine pesos in damages from Eulogia Rias and Maximo Requiroso. Navales alleged that the defendants, without just cause, ordered the destruction of his house, which was built on Rias’ land. The house was described as 6 meters in height, with an area of 8.70 square meters, constructed of wood with a nipa roof, and valued at 1,000 pesos. Navales further claimed he had suffered an additional 200 pesos in prejudice due to the defendants’ refusal to reimburse him. The destruction occurred in April 1904. The defendants denied all allegations and sought dismissal of the complaint.
The Court of First Instance of Cebu rendered a judgment declaring that a prior decision by the justice of the peace of Naga, the order of execution thereof, and the actions of the deputy sheriff, Luciano Bacayo, were illegal. The court found the defendants liable for damages amounting to 500 pesos and sentenced them to pay this sum to Navales, along with costs. The defendants moved for reconsideration and a new trial, arguing the decision was against the weight of the evidence. This motion was denied, and an exception was taken.
The present litigation arose from the execution of a judgment rendered by the justice of the peace in an ejectment action. The house in question was removed from Eulogia Rias’ land by the deputy sheriff in accordance with the justice of the peace’s judgment, which had become final and executory. The order for execution of the final judgment was issued by the justice of the peace.
ISSUE
Whether or not Eulogia Rias and Maximo Requiroso are liable for damages due to the destruction of Vicente Navales’ house, which was demolished by a deputy sheriff pursuant to a final and executory judgment in an ejectment case where Rias was the successful party.
RULING
The Supreme Court reversed the judgment of the Court of First Instance. The Court held that the defendants were not liable for damages as the destruction of the house was a consequence of the execution of a final and executory judgment in an ejectment proceeding. The Court presumed that the deputy sheriff performed his duties regularly and lawfully in executing the judgment, as there was no allegation or proof that he committed trespass or exceeded his functions. Consequently, liability could not be imputed to the party who obtained the valid judgment, nor could damages be compelled from them for the enforcement of that judgment, especially when the party claiming damages was defeated in the original action and was found to be improperly occupying the land. The Court found no proof of a contract, illegal acts, omissions, fault, or negligence on the part of the defendants that would give rise to an obligation to indemnify the plaintiff. The illegality of the justice of the peace’s judgment, the writ of execution, or the sheriff’s actions was not established. Therefore, the complaint for damages was dismissed.
