Go King v. Geronimo
REITERATIONFacts
The Antecedents: Sabino Padilla, owner of lots on Echague Street, Manila, filed an ejectment case against Felipe Aguasin for failure to comply with the lease contract. Aguasin had constructed "barong-barongs" on the lots, which were occupied by sub-lessees, Chinese individuals operating stores. Procedural History: A judgment of eviction was rendered against Felipe Aguasin, which became final and executory. When the sheriff attempted to enforce the order, the sub-lessees, alleging they were not parties to the litigation, petitioned the municipal court to declare that the eviction order did not apply to them. The Petition: The municipal court denied the sub-lessees' request. Consequently, the sub-lessees filed the present petition for prohibition and preliminary injunction to prevent the sheriff from carrying out the execution order. This Court initially declined to issue a restraining order but required respondents to answer.
Issue(s)
Whether an eviction order against a lessee can be enforced against sub-lessees who were not made parties to the ejectment case. Whether the sub-lessees' petition for a declaration that the eviction order did not apply to them constituted a collateral attack on the judgment.
Ruling
The petition is dismissed. The eviction order against the lessee affects the sub-lessees, even if they were not parties to the litigation.
Ratio Decidendi
On the enforceability of the eviction order against sub-lessees: The Court held that the sub-lessees hold the premises subject to the rights of the lessee. Once the lessee's right to the premises disappears, the sub-lessees have nothing to stand on. Their right to occupy is derived from the lessee, and therefore, an eviction order against the lessee necessarily affects them. The Court reiterated the principle that sub-tenants are bound by the judgment against the tenant. The sub-lessees' claim that they were not made parties to the litigation does not exempt them from the effects of a final and executory judgment of eviction against their immediate lessor. Their possession is subordinate to the rights of the owner, and when those rights are judicially determined and enforced, their derivative possession must yield. The Court found no cogent reason in law or logic to deviate from this established principle. On the nature of the sub-lessees' petition: While not explicitly ruled upon as a separate issue, the denial of the sub-lessees' petition by the municipal court implicitly suggests that their request was not a proper remedy. The sub-lessees' attempt to have the eviction order declared inapplicable to them, after the judgment had become final and executory, could be construed as an indirect challenge to the validity or scope of the judgment. However, the primary focus of the Supreme Court's decision was on the substantive right of the sub-lessees and the effect of the eviction order on their possession, rather than the procedural propriety of their motion before the municipal court. The Court's ultimate dismissal of the petition indicates that the sub-lessees' arguments were insufficient to warrant interference with the execution of the judgment.
Main Doctrine
An eviction order against a lessee affects sub-lessees even if they were not made parties to the litigation, as their right to occupy the premises is derived from the lessee and disappears with the lessee's right.