Quilo v. Bajao
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from an ejectment complaint filed by respondent Teodula Bajao against several defendants, including Eduardo B. Saclag, Jr., Zoilo J. Fulong, Sr., Elena Bertos, and Talia Saclag. The complaint sought the eviction and demolition of structures on the property located at 2519 Granate Street, Sta. Ana, Manila. The Metropolitan Trial Court (MeTC) ruled in favor of Bajao, a decision later affirmed by the Regional Trial Court (RTC) and subsequently by the Court of Appeals (CA) and the Supreme Court. 2. Procedural History: Following the finality of the Supreme Court's decision, Bajao filed a motion for execution. After a significant delay, the RTC ordered the remand of the records to the MeTC, which then issued a Writ of Execution. Petitioners Edgardo A. Quilo and Adnaloy Villahermosa, who received a notice to vacate and demolish, filed a motion to quash the writ, arguing it was issued beyond the five-year period and that they were not parties to the original ejectment case. The MeTC denied this motion, asserting the writ bound all occupants. Petitioners then filed a petition for certiorari with the RTC, which was initially denied for failing to attach a certified true copy of the MeTC Decision and for violating the three-day notice rule. A subsequent motion for reconsideration was also denied by the RTC. 3. The Petition: The present petition for review on certiorari under Rule 45 of the Rules of Civil Procedure assails the RTC's dismissal of the certiorari petition. Petitioners argue that the RTC erred in dismissing their certiorari petition for alleged procedural defects, specifically the failure to attach a certified true copy of the MeTC Decision dated November 20, 1998, and for violating the three-day notice rule. They also contend that the MeTC committed grave abuse of discretion in denying their motion to quash the writ of execution. The Supreme Court, however, found that the petitioners resorted to the wrong remedy by filing directly with the Supreme Court instead of the CA, and that their arguments regarding the procedural defects and the execution of the judgment were without merit, ultimately denying the petition.
Issue(s)
Whether the Regional Trial Court committed reversible error in dismissing the petition for certiorari for failure to attach a certified true copy of the MeTC Decision and for violating the 3-day notice rule, and whether the petitioners properly observed the hierarchy of courts. Whether the Metropolitan Trial Court committed grave abuse of discretion in denying the petitioners' motion to quash the writ of execution and recall of the notice to pay/vacate and demolish premises, and whether the ejectment judgment is binding on the petitioners. Whether the writ of execution was issued beyond the reglementary period of five (5) years for executing a judgment, and the effect of the delay on the execution of the judgment.
Ruling
The Supreme Court DENIED the Petition for Review on Certiorari. The petitioners are bound by the Decision of the Metropolitan Trial Court of Manila in Civil Case No. 158273-CV dated 20 November 1998. The Writ of Execution shall be implemented against them immediately upon receipt of this Decision.
Ratio Decidendi
On the procedural issues and hierarchy of courts: The Court held that the petitioners committed a procedural error by filing a petition for review on certiorari directly with the Supreme Court, bypassing the Court of Appeals, thus violating the elementary rule on the hierarchy of courts. The Court emphasized that rules of procedure exist to shield the Court from cases within the competence of lower courts and to enable it to resolve more fundamental issues. While the RTC correctly pointed out the procedural lapses, specifically the failure to attach a certified true copy of the MeTC Decision and the violation of the 3-day notice rule, the Court noted that the submission of certified true copies of the MeTC Orders with the motion for reconsideration constituted substantial compliance. However, the failure to attach a true or plain copy of the MeTC Decision was still considered a procedural defect. On the binding effect of the ejectment judgment on petitioners: The Court affirmed the MeTC's finding that the property occupied by the petitioners (2518 Granate St.) was the same property subject of the litigation (2519 Granate St.). Crucially, the Court reiterated the exception to the rule that judgments are binding only on parties to the case. Ejectment judgments can bind individuals not impleaded if they are trespassers, squatters, agents of the defendant, guests or occupants with the defendant's permission, transferees pendente lite, sublessees, co-lessees, or members of the family, relative, or privy of the defendant. Since the petitioners admitted to being mere lessees of the subject property, they were bound by the MeTC Decision despite not being formally impleaded. On the issuance of the Writ of Execution beyond the reglementary period: The Court acknowledged that the Decision became final and executory on July 28, 2000, giving Bajao five years until July 28, 2005, to move for execution. Bajao timely filed a Motion for Execution on August 8, 2000. However, due to unexplained delays, the writ was not implemented. Bajao's subsequent motion in 2007, filed after the 5-year period for execution by motion, should have been a complaint for revival of judgment under Article 1144(3) of the Civil Code. Nevertheless, the Court, in the exercise of its equity jurisdiction to prevent injustice and to finally settle a protracted case, treated the second motion for execution as a complaint for revival of judgment, finding that the action was filed within the ten-year prescriptive period. The Court reasoned that the delay was not attributable to Bajao, and strict adherence to technical rules would perpetuate injustice.
Main Doctrine
A petition for review on certiorari assailing a judgment involving mixed questions of fact and law must first be brought before the Court of Appeals, adhering to the rule on hierarchy of courts. Furthermore, while procedural rules are essential, the Court may exercise its equity jurisdiction to prevent manifest injustice, such as treating a second motion for execution as a complaint for revival of judgment when the delay in execution was not attributable to the prevailing party.