Spouses Esmilla v. Alvarez
REITERATIONFacts
The Antecedents: Petitioners (Spouses Esmilla) obtained favorable judgments in four ejectment cases (Civil Cases Nos. 38-48535 to 38-48538) before the Metropolitan Trial Court (MTC) of Quezon City, Branch 38. The MTC decision, dated September 3, 1986, was received by private respondents on January 19, 1987. Private respondents filed their notice of appeal on February 5, 1987, which was the 17th day after receipt, thus exceeding the 15-day reglementary period. Petitioners moved for execution, which the MTC granted on February 27, 1987. Procedural History: Private respondents filed a petition for certiorari and prohibition with the Supreme Court (G.R. Nos. 77702-05), which was dismissed on April 8, 1987, holding that certiorari cannot substitute for a lost appeal. Their motion for reconsideration was denied, and entry of judgment was made on June 15, 1987. Meanwhile, the MTC issued an order to implement the writ of execution on June 8, 1987. On June 11, 1987, private respondents filed an action for annulment of the MTC judgment with the Regional Trial Court (RTC) of Quezon City, Branch 102 (Civil Case No. Q-51057), alleging that the properties were covered by Presidential Decree No. 1517 (PD 1517), the urban land reform act, and thus they could not be ejected. The RTC issued a temporary restraining order and later, on July 9, 1987, a writ of preliminary injunction enjoining the execution of the MTC judgment. Petitioners' motion for reconsideration was denied on October 26, 1987. Hence, the present petition for certiorari before the Supreme Court. The Petition: Petitioners seek to annul the RTC's orders granting the writ of preliminary injunction and denying their motion to dismiss, alleging grave abuse of discretion. They contend that the MTC judgment, having become final and executory, bars the action for annulment under the doctrine of res judicata.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion in issuing a writ of preliminary injunction to enjoin the execution of a final and executory MTC judgment. Whether the MTC judgment in the ejectment cases is void for lack of jurisdiction due to the properties being covered by PD 1517.
Ruling
The petition is GRANTED. The Regional Trial Court's order granting the writ of preliminary injunction and its subsequent order denying the motion for reconsideration are annulled and set aside. Civil Case No. Q-51057 before the respondent court is ordered DISMISSED, and the temporary restraining order is made PERMANENT.
Ratio Decidendi
On the issue of whether the RTC committed grave abuse of discretion in issuing the writ of preliminary injunction: The Supreme Court held that the RTC committed grave abuse of discretion. The MTC judgment in the ejectment cases had already become final and executory. The private respondents' failure to file their appeal within the reglementary period meant that the MTC decision attained finality. The subsequent filing of a petition for certiorari and prohibition with the Supreme Court, which was dismissed, further affirmed the finality of the MTC judgment. The Court reiterated the principle that a petition for certiorari cannot be a substitute for a lost appeal. Therefore, the action for annulment of judgment filed with the RTC was an indirect attempt to assail a judgment that had already become final and executory. The Court emphasized that what cannot be done directly should not be allowed to be done indirectly. The RTC's issuance of a writ of preliminary injunction to stay the execution of a final and executory judgment was an act that amounted to grave abuse of discretion, as it effectively allowed the private respondents to circumvent the established legal processes and the finality of the MTC decision. On the issue of whether the MTC judgment is void for lack of jurisdiction due to PD 1517: The Supreme Court found no merit in the private respondents' submission that the MTC lacked jurisdiction because the properties were covered by PD 1517. While PD 1517 provides protection to tenants of residential lands who have occupied their premises for at least ten years, granting them the right of first refusal to purchase the land or providing for government acquisition through expropriation if they are unable to purchase, these rights are contingent upon specific circumstances. The Court clarified that these rights under PD 1517 are primarily invoked when the owner of the property intends to sell it to a third party. A legitimate tenant of at least ten years standing may not be ejected only if they decide to purchase the property intended for sale by its owner. The Court found no evidence that the private respondents had committed fraud upon the petitioners, that the MTC lacked jurisdiction over the subject matter and the parties, or that the MTC decision was patently void on its face. Therefore, the MTC judgment, which had attained finality, could not be set aside on the grounds raised by the private respondents. The Court concluded that the private respondents' claim under PD 1517 did not divest the MTC of its jurisdiction to hear and decide the ejectment cases.
Main Doctrine
An action for annulment of a final and executory judgment cannot be used as a substitute for a lost appeal or as an indirect means to assail a judgment that has already attained finality, absent fraud, lack of jurisdiction, or patent voidness on its face.