Spouses De La Cruz v. Honorable Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioners, Spouses Epifanio de la Cruz and Librada Principe, obtained a P20,000.00 loan from the Philippine National Bank (PNB) in 1957, securing it with a mortgage on two lots. Upon their failure to repay the loan despite demands, PNB extrajudicially foreclosed the mortgage on September 6, 1961, and purchased the lots at auction. The petitioners failed to exercise their right of redemption within the one-year period, leading to the consolidation of titles in PNB's name in October 1962. Subsequently, PNB sold the lots to spouses Conrado and Mariana de Vera in June 1970. Despite the sale, the de Vera spouses could not take possession, prompting PNB to file an ejectment suit against the petitioners on August 16, 1977, after earlier demands to vacate were ignored. 2. Procedural History: The ejectment suit was filed by PNB before the Municipal Court of Bocaue. The petitioners' motion to dismiss was denied, as was their motion for reconsideration. While the ejectment case was pending, the petitioners filed an action for reconveyance of titles against PNB before the Court of First Instance of Bulacan. Meanwhile, PNB's motion to strike out the petitioners' answer in the ejectment suit was granted, leading to the petitioners being declared in default. A judgment was rendered in favor of PNB in the ejectment case on March 16, 1972. The petitioners appealed this judgment to the Court of First Instance, where their appeal was initially dismissed for failure to appear at pre-trial but was later reinstated. After further non-appearances by the petitioners, the case was submitted for decision, and judgment was rendered in favor of PNB on July 10, 1975, ordering the petitioners to vacate. PNB's motion for execution was granted, and a writ of execution was issued. The petitioners' subsequent motions to reconsider the execution and to remand the case to the municipal court were denied. This led the petitioners to file a petition for certiorari and prohibition with the Court of Appeals. 3. The Petition: The petitioners filed a petition for certiorari with the Court of Appeals, seeking to annul the orders of the lower courts, particularly the order granting PNB's motion for the issuance of an alias writ of execution. They contended that the lower courts lacked jurisdiction to decide the ejectment case due to the pendency of their action for reconveyance of titles, arguing that the resolution of possession was dependent on the issue of ownership. The Court of Appeals dismissed their petition for lack of merit. The petitioners then filed the instant petition for review, raising similar arguments that the lower courts acted without jurisdiction and committed grave abuse of discretion by proceeding with the ejectment case and issuing the writ of execution while the reconveyance case was pending. They specifically argued that the issue of ownership was intrinsically linked to possession, divesting the inferior court of jurisdiction.
Issue(s)
Whether the inferior and lower courts acted without jurisdiction in deciding the ejectment case despite the pendency of the action for reconveyance of titles, including the issue of ownership being raised. Whether the lower court committed grave abuse of discretion or exceeded its jurisdiction when it granted the respondent bank's motion for the issuance of an alias writ of execution. Whether the respondent Court of Appeals erred in dismissing the petition filed before it and in lifting the restraining order.
Ruling
The petition is dismissed for lack of merit. The Court of Appeals did not err in upholding the jurisdiction of the lower courts and the issuance of the alias writ of execution.
Ratio Decidendi
On the jurisdiction of the inferior courts over the ejectment case and the issue of ownership being raised: The Court held that an unlawful detainer action falls within the original and exclusive jurisdiction of municipal courts. Petitioners themselves admitted this. While petitioners argued that the ejectment case should have been suspended due to the pending reconveyance action, the Court clarified that an unlawful detainer action concerns only material possession (de facto), whereas a reconveyance action concerns ownership. The pendency of a reconveyance action does not divest the municipal court of its jurisdiction over an ejectment case, nor does it bar the execution of the ejectment judgment when only material possession is at issue. The Court emphasized that judgments in ejectment cases are effective only with respect to possession and do not bind title or affect ownership. The Court reiterated the well-settled rule that inferior courts are not automatically divested of jurisdiction over ejectment cases simply because the defendant claims ownership. However, if possession cannot be resolved without passing upon the issue of ownership because the latter is inseparably linked with the former, then the inferior court loses jurisdiction. In this case, the Court found that PNB was the undisputed owner at the time of the ejectment suit, having lawfully acquired the property through a public auction sale after petitioners failed to exercise their right of redemption. Petitioners' action for reconveyance was filed nine years after the consolidation of ownership, and PNB's title was not seriously controverted. Therefore, the ownership set up by petitioners was merely a claim without a concrete basis in fact and law, which did not preclude the municipal court from assuming jurisdiction. On the alias writ of execution: The Court found no merit in the contention that the lower court committed grave abuse of discretion in granting the alias writ of execution. Given that the ejectment case was lawfully decided in favor of PNB and the CFI affirmed this judgment, the issuance of a writ of execution, including an alias writ, to enforce the lawful judgment is a matter within the court's discretion and ministerial duty. The petitioners' repeated failures to appear and their dilatory tactics further supported the necessity and propriety of issuing the writ to give effect to the final judgment. There was no specific ratio provided regarding the Court of Appeals' decision to dismiss the petition and lift the restraining order. The provided text focuses on the jurisdiction of the lower courts and the propriety of the alias writ of execution. Therefore, no corresponding ratio is available for this issue.
Main Doctrine
The pendency of an action for reconveyance of title over the same property does not divest the city or municipal court of its jurisdiction to try an unlawful detainer case, nor does it preclude the execution of the judgment in the ejectment case where the only issue involved is material possession.