**Facts:**
On March 8, 1989, petitioners Simeona Prescilla and others (collectively, petitioners) initiated a `Complaint for Reconveyance and Damages` against respondents Conrado Lasquite and Juanito Andrade in the Regional Trial Court (RTC) of San Mateo, Rizal, Branch 77 (docketed as Civil Case No. 548). The petitioners claimed long-term possession and ownership of parcels of land designated as Lot No. 3050 and Lot No. 3052, located at Barrio Ampid, San Mateo, since 1940. Petitioners argued that the respondents fraudulently obtained original certificates of titles for the lands: Lasquite with OCT No. NP-198 and Andrade with OCT No. NP-197.
A `Complaint in Intervention` was filed in June 1993 by Roberto and Raquel Manahan and others (collectively, the Manahans), asserting that they had title over the land as successors to Jose S. Manahan. The case was consolidated with Civil Case No. 548. Victory Hills, Inc. intervened as well, claiming ownership of the subject property.
On July 2, 2002, the RTC decision upheld petitioners’ ownership of Lot No. 3052 while sustaining respondents’ titles over Lot No. 3050. Petitioners, the Manahans, and Victory Hills appealed to the Court of Appeals (CA), Eighth Division, which annulled the RTC’s decision on November 8, 2006, declaring Victory Hills the owner of Lot No. 3050.
Respondents Lasquite and Andrade appealed to the Supreme Court (SC) in G.R. No. 175375, while petitioners filed a Motion for Reconsideration with the CA. Upon awareness of the appeal, the CA suspended the resolution of the Motion for Reconsideration pending final decision by the SC.
On June 23, 2009, the SC reversed the CA’s decision, reinstating the RTC’s decision. The final ruling prompted respondents to seek a writ of execution on November 22, 2010. The RTC granted the motion on April 8, 2011, which was contested by petitioners but ultimately denied.
Petitioners then filed a Petition for Certiorari under Rule 65 at the CA’s Seventh Division (docketed as CA-G.R. SP No. 122109), asserting grave abuse of discretion by the RTC. The CA’s Seventh Division upheld the RTC’s decision, prompting petitioners to appeal to the SC.
**Issues:**
1. Whether the RTC committed grave abuse of discretion by issuing a Writ of Execution against petitioners.
2. Whether the CA erred in denying petitioners’ Motion for Reconsideration.
3. The procedural implications of unresolved motions for reconsideration.
**Court’s Decision:**
1. **Grave Abuse of Discretion by RTC**: The SC found merit in the petition, concluding that the RTC committed grave abuse of discretion. Since petitioners’ motion for reconsideration in the CA remained unresolved due to suspension from the CA’s Eighth Division, the execution of the judgment as to petitioners was premature.
2. **CA’s Denial of Motion for Reconsideration**: The SC criticized the CA, Seventh Division, for ignoring the legal principle that an unresolved motion for reconsideration stays the execution of the judgment. Petitioners had not had their day in court to address their ownership claims separately from the Victory Hills’ issue.
3. **Procedural Implications**: The SC emphasized the due process violations from the CA’s failure to timely resolve motion for reconsideration and stressed the importance of addressing outstanding appeals before enforcing writs of execution.
**Doctrine:**
1. **Stay of Execution**: Section 4, Rule 52 of the Rules of Court prevents execution of a judgment when a motion for reconsideration is still pending.
2. **Due Process in Civil Actions**: A party cannot be bound by a ruling unless it was fully represented and had the opportunity to contest the issues involved, ensuring protection of due process rights.
**Class Notes:**
– **Stay of Execution**: To forestall execution, ensuring compliance with timelines for motion for reconsideration can defer enforcement of potentially erroneous decisions.
– **Due Process in Civil Proceedings**: A judgment is binding only on involved parties, ensuring that uninvolved or inadequately represented parties are not prejudiced.
– **Prohibiting Execution against Non-Parties**: Cemented by Guy v. Gacott (2016), courts cannot execute judgments against those who didn’t have their claim adjudicated.
**Historical Background:**
The case highlights systemic issues in property disputes in the Philippines, specifically the complexity arising from overlapping claims and fraudulent title acquisitions. This controversy demonstrates procedural difficulties, due process protections, and efficiency challenges within the legal framework, emphasizing the judiciary’s role in clarifying such ambiguities and ensuring fair outcomes.
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