Besa v. Tiongson
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a collection case filed by Stasa Incorporated (Stasa), the lessor, against Mamerto B. Besa, the lessee, for reimbursement of P2,352.00 representing electrical consumption for an apartment from May 21, 1978, to August 20, 1985. Stasa had advanced this payment on behalf of Besa. 2. Procedural History: Stasa filed an action for collection of a sum of money against Besa in the Metropolitan Trial Court (MTC) of Manila. A judgment was rendered in favor of Stasa, which became final and executory. When Stasa moved for execution, Besa opposed, claiming he did not receive a copy of the decision. The MTC ordered him to be served a copy. Despite this, Besa later filed a manifestation alleging that a Supreme Court resolution in a separate ejectment case (G.R. No. 82596) found him not to be the lessee, but rather Victoria Justiniano. The MTC denied Besa's opposition and motion for reconsideration, ruling that the collection case was distinct from the ejectment case and its final judgment could be executed. 3. The Petition: Besa filed a petition for certiorari with the Supreme Court, raising alleged errors of the respondent judge. These included the judge's assertion that the decision was final and executory, failure to consider Supreme Court decisions as part of the legal system, exceeding authority by ordering payment when Besa claimed not to be a lessee, and lack of jurisdiction. Besa argued that the Supreme Court's finding in the ejectment case that he was not the lessee precluded the execution of the collection judgment against him.
Issue(s)
Whether the decision in the collection case had become final and executory. Whether a decision of the Supreme Court in an ejectment case could prevent the execution of a final and executory judgment in a separate collection case. Whether the respondent judge exceeded his authority in ordering the petitioner to pay for electrical consumption when the petitioner was allegedly not a lessee. Whether the respondent court had jurisdiction over the person of the petitioner and the issue of the case.
Ruling
The petition is devoid of merit. The Supreme Court dismissed the petition with treble costs against the petitioner.
Ratio Decidendi
On the finality and executory nature of the decision: The Court found that the judgment in the collection case had indeed become final and executory. The petitioner's claim that he did not receive a copy of the decision was given no credence, especially since the court ordered him to be furnished a copy in open court, and he later acknowledged its finality by filing a manifestation based on a Supreme Court resolution. His subsequent denial of receipt could not be given credence. On the effect of the Supreme Court decision in the ejectment case: The Court held that the cause of action in the collection case was different and distinct from that in the ejectment case. Therefore, the enforcement of the collection case could not be prevented by the independent judgment of the Supreme Court in the ejectment case. The principle of res judicata does not apply when the causes of action are distinct. On the petitioner's status as a lessee and the judge's authority: The Court found the petitioner's claim that he was not a lessee to be a sham allegation. It was revealed that Victoria Justiniano, who was determined to be a co-lessee in the ejectment case, was the petitioner's common-law wife. Since they occupied the apartment together, the petitioner was equally liable with Justiniano to reimburse the lessor for the electrical consumption. The lessor's advance payment created an inescapable duty for the petitioner to reimburse. On jurisdiction: The Court implicitly affirmed jurisdiction by ruling on the merits of the case. The argument regarding lack of jurisdiction was deemed without merit as the collection case proceeded to a final and executory judgment, and the petitioner participated in the proceedings, albeit with oppositions that were found to be without basis.
Main Doctrine
A final and executory judgment in a collection case can be enforced independently of a separate and distinct ejectment case, even if the latter involves a determination of the parties' relationship to the property.