Cordero v. Gutierrez Development Co.
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land in Davao City registered under Gutierrez Development Co., Inc. (respondent). Petitioners had been occupying the land, initially by tolerance, and later paying a nominal monthly rental of PHP 100.00. When respondent acquired the property, it continued this arrangement. However, respondent alleged that petitioners neglected their rental obligations. Consequently, respondent filed a petition to fix the lease period and adjust rentals, seeking a lease term not exceeding one year at a rate reflecting the land's current value, and for other equitable relief. Petitioners, in defense, claimed failed negotiations for lease extension or payment for improvements. They counterclaimed for PHP 46,500,000.00 for improvements and damages. 2. Procedural History: The Regional Trial Court (RTC) of Davao City, Branch 13, in its August 31, 2006 Decision, fixed the monthly rental at PHP 100.00 for a two-year period from the date of the decision, emphasizing that the lessor-lessee relationship could not continue indefinitely. The Court of Appeals (CA), in its September 25, 2008 Decision, affirmed the RTC ruling but deemed the lease terminated as the two-year period had already expired, ordering petitioners to vacate. This CA ruling became final and executory. Subsequently, respondent filed a motion for execution, which the RTC granted on September 18, 2009, issuing a writ of execution. Petitioners' motion for reconsideration, arguing the two-year period should commence from the CA ruling's finality, was denied by the RTC on May 15, 2010. Petitioners then filed a Rule 65 petition for certiorari with the CA, seeking a TRO and/or WPI. 3. The Petition: The consolidated petitions before the Supreme Court are filed under Rule 45 of the Rules of Court. G.R. No. 205074 assails the CA's Resolutions dated December 29, 2011, and November 19, 2012, which denied petitioners' prayer for a temporary restraining order (TRO) and/or writ of preliminary injunction (WPI) in their Rule 65 petition. G.R. No. 231518 assails the CA's Decision dated June 22, 2016, and Resolution dated March 23, 2017, which affirmed the RTC's Orders directing the issuance of a writ of execution. Petitioners argue that the RTC gravely abused its discretion in ordering execution based on a final and executory CA ruling, particularly concerning the commencement of the lease termination period. The Supreme Court, however, found the petition in G.R. No. 205074 moot and academic due to the resolution of the main case and denied G.R. No. 231518 for lack of merit, upholding the immutability of the final CA judgment.
Issue(s)
Whether the CA correctly denied petitioners' prayer for a temporary restraining order (TRO) and/or writ of preliminary injunction (WPI) in G.R. No. 205074. Whether the CA correctly found no grave abuse of discretion on the part of the RTC in issuing Orders directing the issuance of a Writ of Execution in favor of respondent, pursuant to the CA ruling in CA-G.R. CV No. 00991-MIN, in G.R. No. 231518.
Ruling
The Petition in G.R. No. 205074 is dismissed for being moot and academic. The Petition in G.R. No. 231518 is denied for lack of merit. The Decision dated June 22, 2016, and the Resolution dated March 23, 2017, of the Court of Appeals in CA-G.R. SP No. 03631-MIN are affirmed.
Ratio Decidendi
On the issue of the denial of TRO/WPI (G.R. No. 205074): The Court dismissed the petition as moot and academic. It reiterated the rule that an appeal or petition for certiorari assailing a mere incident in a main case becomes moot and academic upon the resolution of the main case on the merits. In this instance, the CA's resolution on the merits of CA-G.R. SP No. 03631-MIN rendered the issue of the propriety of denying the TRO/WPI prayer moot. The Court cited Philippine Veterans Bank v. Court of Appeals to support the principle that a judgment will not serve any useful purpose if the main issue has already been resolved, making the adjudication of the incident purely an academic exercise. On the issue of grave abuse of discretion in issuing the Writ of Execution (G.R. No. 231518): The Court denied the petition for lack of merit, affirming the CA's finding that the RTC did not gravely abuse its discretion. The CA's ruling in CA-G.R. CV No. 00991-MIN had long become final and executory, rendering it immutable. The Court emphasized the doctrine of immutability of judgment, stating that a final decision becomes unalterable, even to correct errors of fact or law, to ensure orderly judicial business and put an end to controversies. The issuance of a writ of execution upon a final and executory judgment is a matter of right and a ministerial duty of the court, as provided under Rule 39, Section 1 of the Rules of Court. The Court cited Aguinaldo IV v. People and Mauleon v. Porter to underscore that once a judgment is final, the prevailing party is entitled to its fruits, and delay in enforcement is unjust. The RTC's actions were in strict accordance with the final CA ruling, thus no grave abuse of discretion was committed.
Main Doctrine
A petition assailing a mere incident in a main case, such as the denial of a temporary restraining order or writ of preliminary injunction, becomes moot and academic upon the resolution of the main case on the merits. Furthermore, a writ of execution must be issued as a matter of right once a judgment becomes final and executory, and the court's duty to issue it is ministerial.