Balintawak Construction Supply Corp. v. Valenzuela
REITERATIONFacts
1. The Antecedents: The underlying dispute involves an ejectment case filed by Balintawak Construction Supply Corporation (Balintawak) against GM Wood Export Industries, Inc. (GM Wood) for non-payment of rentals on leased premises. GM Wood was declared in default, and the City Court of Caloocan rendered a judgment ordering GM Wood to vacate the premises and pay substantial back rentals, attorney's fees, and costs. Separately, Traders Royal Bank filed a collection case against GM Wood, leading to a writ of attachment issued by the Court of First Instance (CFI) of Rizal against GM Wood's properties, including those located on the leased premises. 2. Procedural History: GM Wood's attempt to challenge the default judgment and the writ of execution in the ejectment case through certiorari petitions at the CFI and later at the Supreme Court (G.R. No. L-54410) were dismissed for lack of merit. Despite the finality of the ejectment judgment, GM Wood filed a manifestation and motion in the CFI case, requesting an injunction against the sheriff from disturbing the attached properties due to the ejectment order. The CFI Judge issued an order directing the sheriff to desist from interfering with the attached properties. Balintawak's motion for reconsideration of this order was denied by the CFI Judge, prompting the filing of the present petition. 3. The Petition: This case is a Petition for certiorari and Prohibition with Preliminary Injunction filed by Balintawak Construction Supply Corporation. Balintawak seeks to annul the Orders of the CFI Judge dated April 29, 1981, and June 5, 1981, arguing that the CFI Judge acted with grave abuse of discretion tantamount to lack or excess of jurisdiction in enjoining the enforcement of a final and executory ejectment judgment from a lower court. Balintawak contends that the CFI Judge's order effectively prevented the execution of a valid and final judgment, which is a ministerial duty of the court, and that the attached properties, while belonging to GM Wood, were located on premises whose possession rightfully belonged to Balintawak by virtue of the ejectment judgment.
Issue(s)
Whether the respondent Judge of the Court of First Instance of Rizal acted with grave abuse of discretion tantamount to lack of or excess of jurisdiction in enjoining the enforcement of a final and executory judgment for ejectment of the City Court of Caloocan. Whether the machineries, assorted lumber, and office equipment subject to the attachment order belong to GM WOOD, and whether the leased premises, which do not belong to GM WOOD, should be subject to the attachment order.
Ruling
The Supreme Court annulled and set aside the Orders issued by the respondent Judge, dated April 29, 1981, and June 5, 1981. The Metropolitan Trial Court, corresponding to the former City Court of Caloocan, was directed to proceed with the enforcement of the Alias Writ of Execution in Civil Case No. 13446. The temporary restraining order issued by the Supreme Court was made permanent.
Ratio Decidendi
On the issue of grave abuse of discretion in enjoining the enforcement of a final and executory judgment: The Supreme Court held that the respondent Judge of the Court of First Instance of Rizal acted with grave abuse of discretion tantamount to lack of or excess of jurisdiction in enjoining the enforcement of a final and executory judgment for ejectment rendered by the City Court of Caloocan. It is a basic legal principle that once a judgment becomes final and executory, the prevailing party is entitled as a matter of right to a writ of execution, and its issuance is a ministerial duty of the court, compellable by mandamus. The Court emphasized that an execution is the fruit and end of a suit, considered the very life of the law. Therefore, petitioner BALINTAWAK, as the prevailing party, was entitled as a matter of right to the execution of the ejectment judgment in its favor, which had become final and executory. The respondent Judge's order effectively defeated this right. On the ownership of properties and the scope of attachment: The Court noted that the machineries, assorted lumber, and office equipment, which were the subject of the attachment order, belonged to GM WOOD. However, the leased premises themselves did not belong to GM WOOD; the building belonged to petitioner BALINTAWAK as the lessor. Consequently, the leased premises should not have been subject to the attachment order issued by the respondent Judge. The right to possession of the leased premises belonged to petitioner BALINTAWAK by virtue of the final judgment in its favor, and the respondent Judge could not defeat that right through an attachment order concerning properties within the premises. Furthermore, the Court observed that GM WOOD did not follow the correct procedure by filing a third-party claim to defeat the Writ of Execution.
Main Doctrine
A respondent judge commits grave abuse of discretion tantamount to lack of or excess of jurisdiction when he enjoins the enforcement of a final and executory judgment for ejectment rendered by an inferior court, as the prevailing party is entitled as a matter of right to a writ of execution.