Suson v. Court of Appeals
REITERATIONFacts
1. The Antecedents: This case stems from a complaint for recovery of a portion of Lot 2051 and for quieting of title, filed by Cerila Besabella, et al. against spouses Isaac and Leoncia Soco. The Regional Trial Court of Cebu, Branch VI, ruled in favor of the Soco spouses, a decision later affirmed by the Court of Appeals. Subsequently, the Soco spouses sought the demolition of improvements on the disputed property. 2. Procedural History: During the execution phase of the initial judgment, it was discovered that petitioner Luis Suson, who was not an original party, had constructed a house on a portion of Lot 2051. The respondent court ordered Suson to file a complaint in intervention, which he failed to do. Consequently, an order for demolition of his house was issued. Suson's subsequent motions and appeals, including an appeal with the original plaintiffs to the Court of Appeals and this Court (G.R. No. 74205), were denied. Separately, Suson filed a complaint for quieting of title (Civil Case No. R-22651), which was also dismissed and subsequently affirmed by this Court. 3. The Petition: Petitioner Luis Suson seeks a writ of certiorari challenging the respondent Regional Trial Court's order dated October 20, 1982, which directed the demolition of his house. He argues that this order effectively amended a final judgment. The petition also assails the dismissal of his separate complaint in Civil Case No. R-22651. The core issue is whether the respondent court gravely abused its discretion in ordering the demolition of Suson's house after he failed to intervene, despite being given the opportunity.
Issue(s)
Whether the respondent Regional Trial Court (Branch VI) acted with grave abuse of discretion amounting to lack of jurisdiction, or acted in excess of its jurisdiction, when it issued the order dated October 20, 1982, in Civil Case No. R-14351, ordering petitioner to demolish his house on the questioned lot. Whether the second action (Civil Case No. R-22651) filed by petitioner is barred by prior judgment (res judicata).
Ruling
The petition is DISMISSED. The Order of the respondent court dated October 20, 1982, is AFFIRMED. The order of the Regional Trial Court of Cebu, Branch X, dated May 8, 1987, issued in Civil Case No. R-22651, is also AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the issue of grave abuse of discretion and the demolition order: The Supreme Court held that the RTC acted within its power. The hearing on the motion for demolition was part of the execution of a final judgment. Petitioner Suson was given an opportunity to intervene to present his claim regarding his house on the disputed property, but he failed to do so. His failure to avail of this opportunity meant he could not later claim denial of due process. The Court reiterated that a court retains supervisory control over its process of execution and has the right to determine all questions of fact and law involved therein. Furthermore, the Court cited jurisprudence holding that a writ of execution may be issued against a non-party if their remedy was to intervene and they failed to do so. By joining the plaintiffs in appealing the orders, including the demolition order, to the CA and subsequently to the Supreme Court, petitioner placed himself within the jurisdiction of the respondent court and became bound by its judgments and orders. The final and executory nature of the original judgment meant its execution could not be postponed. On the issue of res judicata: The Supreme Court found that Civil Case No. R-22651 was barred by prior judgment. An examination of the record and arguments revealed no new substantial issues or evidence were raised in the second action compared to the first. The parties were essentially the same (petitioner joined the original plaintiffs), the subject matter (Lot 2051) was identical, and the causes of action were basically the same. The Court affirmed the principle that a party cannot escape the effects of res judicata by merely varying the form of action or the method of presenting the case. Therefore, the RTC Branch X correctly dismissed petitioner's complaint in Civil Case No. R-22651.
Main Doctrine
A court acts within its power when it orders the demolition of a structure on disputed property after the owner failed to intervene in the case to assert their claim, especially when the owner later joins the appeal of the original parties, thereby submitting to the court's jurisdiction.