San Pedro v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent William Ledesma filed an unlawful detainer case against petitioner spouses Pedie and Cecilia Loresto. The Metropolitan Trial Court (MTC) ruled in favor of Ledesma, ordering the spouses to vacate the premises, pay P12,000.00 monthly as reasonable compensation, and pay attorney's fees and costs. Procedural History: The spouses appealed to the Regional Trial Court (RTC). Subsequently, the spouses, along with petitioner Catalino San Pedro, filed an action for annulment of Ledesma's title over the property, claiming it was titled under Titulo Propriedad No. 4136 in the name of Don Mariano San Pedro and possessed by San Pedro's predecessors since 1900. Ledesma filed a motion for execution pending appeal due to the spouses' failure to make the periodic P12,000.00 deposits. The RTC granted the motion, issuing a writ of execution and notice to vacate. The spouses and San Pedro filed a petition for certiorari, mandamus, and prohibition with the Court of Appeals (CA), which was denied. Their motion for reconsideration was also denied, leading them to file a petition for certiorari with prohibition and preliminary injunction with the Supreme Court. The Petition: Petitioners seek to annul the CA's decision affirming the RTC's order for execution pending appeal, arguing that the execution could not be ordered due to the pendency of their annulment suit and that the unlawful detainer case was not the proper remedy.
Issue(s)
Whether the respondent Court of Appeals committed grave abuse of discretion in affirming the order of the Regional Trial Court directing the execution of the judgment in the unlawful detainer case pending appeal. Whether the pendency of an action for annulment of title involving the same property should abate an ejectment suit or bar the execution of the judgment therein.
Ruling
The petition is denied for lack of merit. The Court affirmed the CA's decision, upholding the execution of the judgment in the unlawful detainer case pending appeal.
Ratio Decidendi
On the issue of execution pending appeal: Judgments in ejectment cases favorable to the plaintiff are immediately executory and can only be stayed by the defendant perfecting an appeal, filing a supersedeas bond, and making periodic deposits of the rental or reasonable compensation for the use and occupation of the property during the pendency of the appeal. These requisites must concur. In this case, the petitioner spouses failed to make the required monthly deposits of P12,000.00 and did not claim any exception. Therefore, the lower court did not err in complying with its ministerial duty to issue the writ of execution pending appeal. The respondent Court of Appeals also acted correctly in sustaining the issuance of the writ, as no lack of jurisdiction or grave abuse of discretion was committed. On the issue of the pendency of the annulment suit: The argument that the execution of the ejectment decision could not be ordered because of the pendency of the annulment suit is untenable. It is a firmly settled rule that the pendency of an action questioning the ownership of property will not abate ejectment suits or bar the execution of the judgments therein. This principle has been applied in various cases involving injunction suits, consignation of rentals, accion publiciana, writ of possession cases, actions for quieting of title, suits for specific performance, actions for reformation of instrument, actions for reconveyance, and suits for annulment of sale or title. The rationale is that an ejectment suit involves only the issue of material possession or possession de facto, while an action for annulment of title involves the question of ownership. Despite the identity of parties and subject matter, the causes of action and reliefs prayed for are different.
Main Doctrine
The pendency of an action questioning the ownership of property will not abate ejectment suits or bar the execution of the judgments therein, as ejectment suits involve only material possession while ownership cases involve title.