Oblea vs. Court of Appeals

The subsequent acquisition of ownership over property subject of an ejectment case is not a "supervening event" that bars execution of a final and executory judgment in an unlawful detainer case, the sole issue in ejectment being possession de facto and not possession de jure.

The disputed lot, designated as Lot 1, Block 2, was formerly part of a mother lot covered by TCT No. 26604 of the Register of Deeds of Cabanatuan City, containing 83,325 square meters and registered in the names of Manuel Melencio (1/3), Pura Melencio (1/3), and Wilfredo Wico and Mariabelle M. Wico (1/3). TCT No. 26604 was subsequently cancelled and TCT No. 65031 was issued in the name of petitioner Ramon S. Melencio, who became a co-owner with Pura Melencio and the Wicos by virtue of a deed of sale executed in his favor by his deceased father Manuel Melencio.

On 6 June 1958, private respondent Juan S. Esteban bought the subject lot from Mauricio Ramos, who claimed to have acquired the property from Ursula Melencio, the alleged administratrix of the estate of Manuel and Pura Melencio. Petitioner Romeo V. Oblea thereafter leased a building located on the subject lot from a certain Marius Esteban, an alleged son of private respondent Juan S. Esteban. Oblea eventually bought from Marius the lot on which the building stood.

As a consequence, on 4 July 1991 Esteban filed an ejectment suit against Oblea in the Municipal Trial Court of Cabanatuan City, docketed as Civil Case No. 10588. On 3 April 1992, the MTC rendered judgment in favor of Esteban, ordering Oblea to vacate the premises and pay rental arrears from January 1983, as well as litigation expenses and attorney's fees in the total sum of ₱8,000.00. On appeal, the RTC modified the decision on 26 March 1993 by ordering Oblea to pay rentals only from 2 March 1988, but sustained the MTC in all other respects.

On 3 June 1993, the registered owners — Pura Melencio, Wilfredo Wico, and Mariabelle Wico — sold the disputed lot to petitioner Oblea. Thereafter, Oblea together with Ramon Melencio, Pura Melencio, Wilfredo Wico, and Mariabelle Wico filed before the RTC an action for quieting of title against Esteban, docketed as Civil Case No. 1536, contending that the deeds of sale executed by Mauricio Ramos in favor of Juan Esteban and by Ursula Melencio in favor of Mauricio Ramos were a nullity.

Meanwhile, the ejectment case had been appealed to the Court of Appeals by way of petition for review, which was dismissed on 2 July 1993. Upon remand of the records, and on motion of Esteban as the prevailing party, MTC Judge Lydia B. Hipolito directed execution and issued the corresponding writ to enforce the final and executory judgment. The execution was thwarted when petitioners filed a petition for certiorari and prohibition with application for a temporary restraining order and preliminary injunction before the RTC, docketed as Civil Case No. 1676-AF. On 22 November 1993, the Executive Judge issued a temporary restraining order stopping enforcement of the writ. On 6 April 1994, however, Acting Presiding Judge Adriano I. Tuason of Br. 27 lifted and cancelled the restraining order, paving the way for execution. Petitioners then elevated the matter to the Court of Appeals, which dismissed their appeal on 27 September 1994 on the ground that the eviction case had long become final and executory and that the various actions taken by petitioners were merely designed to delay execution.

• Supervening Event Doctrine: Petitioners maintained that their subsequent purchase of the disputed lot on 3 June 1993 constituted a "supervening event" that gave them a better right of possession and ownership, thereby barring enforcement of the ejectment judgment.
• Pendency of Quieting of Title Action: Petitioners argued that the institution of a separate action for quieting of title before the RTC should prevent execution of the ejectment judgment, as the deeds of sale underlying Esteban's claim were allegedly nullities.

• Supervening Event: Whether the subsequent acquisition of ownership by petitioners over the disputed lot constitutes a "supervening event" that bars execution of the final and executory judgment in the ejectment case.
• Effect of Quieting of Title Action: Whether the pendency of an action for quieting of title before the RTC divests the MTC of jurisdiction over the ejectment case or otherwise defeats execution of the final ejectment judgment.

• Supervening Event: No. The subsequent acquisition of ownership by petitioners is not a supervening event that will bar execution of the judgment in the unlawful detainer case, the sole issue in ejectment being possession de facto and not possession de jure.
• Effect of Quieting of Title Action: No. The pendency of an action for quieting of title before the RTC does not divest the MTC of jurisdiction to proceed with the ejectment case over the same property; with the finality of the ejectment decision, execution has become a matter of right and its implementation mandatory.

• Supervening Event: The sole issue in an action for unlawful detainer is physical or material possession — possession de facto — and not possession de jure. This is settled doctrine. When the MTC rendered judgment in the ejectment case, petitioner Oblea was a mere possessor of the subject lot. The subsequent sale of the disputed lot to petitioners on 3 June 1993 does not constitute a supervening event that would bar execution, because the ejectment case never dealt with the issue of ownership. The fact that petitioners instituted a separate action for quieting of title actually bolsters the conclusion that the eviction case did not resolve ownership, which was precisely the subject matter of the quieting of title action before the RTC.
• Effect of Quieting of Title Action: The pendency of an action for quieting of title before the RTC does not divest the city or municipal trial court of its jurisdiction to proceed with the ejectment case over the same property. On the contrary, the separate quieting of title action confirms that the ejectment case did not deal with ownership. With the finality of the decision in the ejectment case, execution in favor of the prevailing party became a matter of right and its implementation mandatory; it cannot be avoided. The Court of Appeals committed no reversible error in upholding the RTC order of 6 April 1994 that lifted the temporary restraining order enjoining implementation of the writ of execution.

• Doctrine of Supervening Event (Inapplicable to Ejectment) — The subsequent acquisition of ownership over property subject of an ejectment case does not constitute a "supervening event" that bars execution of a final and executory judgment, because the sole issue in unlawful detainer is possession de facto, not possession de jure. The Court applied this principle to reject petitioners' claim that their 3 June 1993 purchase of the disputed lot gave them a better right of possession sufficient to enjoin execution of the ejectment judgment.
• Jurisdiction in Ejectment Cases — The pendency of an action for quieting of title before the RTC does not divest the MTC of jurisdiction to proceed with the ejectment case over the same property. The Court relied on this principle to hold that the separate quieting of title action filed by petitioners could not defeat execution of the summary remedy of ejectment, as the two actions addressed distinct issues — possession de facto versus ownership.

• "It must be stressed that the sole issue in an action for unlawful detainer is physical or material possession, i.e., possession de facto and not possession de jure." — This passage articulates the fundamental jurisdictional principle governing ejectment cases, distinguishing the limited scope of MTC ejectment proceedings from actions involving title or ownership.
• "The subsequent acquisition of ownership by petitioners is not a supervening event that will bar the execution of the judgment in said unlawful detainer case, the fact remaining that when judgment was rendered by the MTC in the ejectment case, petitioner Oblea was a mere possessor of the subject lot." — This is the ratio decidendi directly rejecting the supervening event doctrine as applied to post-judgment acquisition of ownership in ejectment cases.
• "With the finality of the decision in the ejectment case, execution in favor of the prevailing party has become a matter of right; its implementation mandatory. It cannot be avoided." — This passage states the mandatory nature of execution once an ejectment judgment becomes final and executory, reinforcing that procedural maneuvers cannot defeat the prevailing party's right to execution.

• Joven vs. Court of Appeals, G.R. No. 80739, 20 August 1992, 212 SCRA 700 — Followed. Cited for the proposition that the pendency of an action for quieting of title before the RTC does not divest the MTC of jurisdiction to proceed with the ejectment case over the same property.
• Hualam Construction and Development Corporation vs. Court of Appeals, G.R. No. 85466, 16 October 1992, 214 SCRA 612 — Followed. Cited for the principle that once a decision in an ejectment case becomes final, execution in favor of the prevailing party becomes a matter of right and its implementation is mandatory.

Padilla, Davide, Jr., and Quiason, JJ., concurred. Kapunan, J., was on leave.