G.R. No. L-7325; July 16, 1954
MACARIO ENRIQUEZ, ET AL., petitioners, vs. HON. ALEJANDRO PANLILIO, in his capacity as the presiding judge of Branch A, Court of First Instance of Manila, the SHERIFF OF MANILA, DEE C. CHUAN CO. INC. and STANDARD VACUUM OIL CO., respondents.

FACTS

Respondent Dee C. Chuan Co. (Chuan Co.) owned a large parcel of land in Manila, a portion of which was leased to respondent Standard Vacuum Oil Co. (Oil Co.). Prior to 1947, without the knowledge and consent of the owner and lessee, petitioners entered the leased portion and erected temporary houses (barong-barong), refusing to leave despite demands. The Oil Co. filed an ejectment suit in the Municipal Court of Manila, obtaining a favorable judgment ordering petitioners to vacate and denying their counterclaim. Petitioners appealed to the Court of First Instance of Manila, which rendered judgment against them on December 27, 1949, ordering them to vacate and pay monthly rentals. This judgment became final and executory. In July 1950, the Republic of the Philippines instituted expropriation proceedings (Civil Case No. 11525) under Commonwealth Act No. 538 concerning a portion of Chuan Co.’s land, including the area leased to the Oil Co. and occupied by petitioners. By order dated April 17, 1951, the Court of First Instance suspended execution of the ejectment judgment due to the expropriation proceedings. In early 1953, Chuan Co. moved to lift the order staying execution. The court granted the motion on February 21, 1953, finding that petitioners were not bona-fide tenants or occupants and had failed to pay or deposit current reasonable rentals, thus not entitled to the benefits of Commonwealth Act No. 538. Petitioners filed a motion for reconsideration only on November 23, 1953, which was denied on November 26, 1953. Petitioners then filed the present petition for certiorari with preliminary injunction, claiming the court acted with grave abuse of discretion.

ISSUE

Whether the respondent judge acted with grave abuse of discretion, amounting to excess of jurisdiction, in issuing the order of February 21, 1953, lifting the suspension of execution of the ejectment judgment, and in denying the motion for its reconsideration.

RULING

The Supreme Court denied the petition for certiorari. It held that the respondent court did not commit any abuse of discretion, much less exceed its jurisdiction. The Court agreed with the trial court and respondents that petitioners were not entitled to the benefits of Commonwealth Act No. 538, particularly Section 1, which provides for automatic suspension of ejectment actions when the government seeks to acquire lands through purchase or expropriation, provided the tenant pays or deposits current rents. The Court found that petitioners were not bona-fide occupants or tenants, as they entered the land without the knowledge and consent of the owner and lessee, no relationship of landlord and tenant was established, and they had not paid anything for their occupation, even after the court’s judgment ordering them to pay. The law contemplates expropriation of lands lawfully occupied under an agreement of tenancy, with tenants paying rentals, to aid lawful occupants by making their occupancy permanent and giving them an opportunity to become owners. This was not the case with petitioners. The writ of preliminary injunction previously issued was dissolved, with costs against petitioners.