Campana Development v. Ledesma
REITERATIONFacts
The Antecedents: Petitioner filed an ejectment case against private respondent Ledesma for failure to vacate premises and pay rentals after the contract of lease expired. Private respondent claimed he had paid rentals and that petitioner no longer had possession rights as the property was foreclosed by the Development Bank of the Philippines (DBP) and was in DBP's possession since March/April 1997, with whom he made arrangements for continued occupation. Procedural History: The Metropolitan Trial Court (MeTC) ruled in favor of petitioner. The Regional Trial Court (RTC) affirmed the MeTC judgment. Petitioner moved for immediate execution, which the RTC granted. Private respondent appealed to the Court of Appeals (CA) via a petition for review on certiorari, seeking a TRO or preliminary injunction. The CA issued a TRO, staying the execution, and later a writ of preliminary injunction. The Petition: The CA, in issuing the writ, reasoned that execution would likely cause injustice, citing its prior ruling in CA-G.R. CV No. 34856 which attained finality, establishing DBP as the present owner. The CA noted that only the owner or those deriving rights from the owner could lawfully eject a tenant, and petitioner did not claim such right. The CA also stated that the rule on estoppel against tenants does not apply if the landlord's title has expired or been conveyed. Petitioner's motion for reconsideration was denied. Petitioner filed the present petition for certiorari, seeking to nullify the CA Resolutions.
Issue(s)
Whether the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in ordering the issuance of a writ of preliminary injunction to stay the immediate execution of the RTC judgment. Whether mandamus lies to compel the RTC Judge to issue a writ of execution; and whether the supersedeas bond posted with the MeTC was sufficient for the CA's writ of preliminary injunction.
Ruling
The petition is dismissed for lack of merit. The Resolutions of the Court of Appeals, dated February 13, 2002 and June 28, 2002, are affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing the writ of preliminary injunction: The Court held that for a writ of certiorari against the CA to issue, petitioner must show grave abuse of discretion, defined as a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. Mere abuse of discretion is insufficient; it must be patent and gross. The Court found no such grave abuse in this case. While Section 21, Rule 70 of the Rules of Court provides that RTC judgments in ejectment cases are immediately executory, jurisprudence, such as in Benedicto v. Court of Appeals, allows the appellate court to stay execution if circumstances require. The CA correctly considered the final and executory decision in CA-G.R. CV No. 34856, which ordered petitioner (formerly La Campana Food Products, Inc.) to surrender possession to DBP, as a supervening event casting serious doubt on petitioner's right of possession. This made the RTC's decision to order private respondent to surrender possession to petitioner questionable and execution inequitable, aligning with the principle in Laurel v. Abalos where supervening events making execution inequitable may warrant a stay. The CA acted prudently by staying execution until a final resolution of the main case. On the issue of mandamus to compel the RTC Judge to issue a writ of execution and the sufficiency of the supersedeas bond: The Court found petitioner's contention that the supersedeas bond posted with the MeTC was insufficient for the CA's writ of preliminary injunction to be incorrect. Section 4(b), Rule 58 of the Rules of Court requires the applicant for an injunction to file a bond to answer for damages sustained by the enjoined party if the injunction is found improper. However, jurisprudence, particularly Hualam Construction and Dev't. Corp. v. Court of Appeals, clarifies that damages in unlawful detainer cases are limited to rent or fair rental value for the use and occupation of the property, not damages unrelated to loss of material possession. Since the only damages petitioner could claim due to the stay of execution would be for rent or fair rental value, the supersedeas bond, which answers for unpaid rentals, was deemed sufficient by the CA to cover potential damages arising from the injunction. Therefore, the CA did not err in considering the supersedeas bond as sufficient.
Main Doctrine
The Court of Appeals may stay the execution of an RTC judgment in an ejectment case if circumstances warrant, particularly when a supervening event casts doubt on the petitioner's right of possession, and the damages recoverable in an unlawful detainer case are limited to rent or fair rental value.