SPS. THELMA R. MASINSIN v. ED VINCENT ALBANO

FACTS:

Spouses Miguel and Thelma Masinsin filed a petition for certiorari, prohibition, relief from judgment, as well as declaratory relief, with prayer for preliminary mandatory injunction, seeking to order the Metropolitan Trial Court ("MTC") of Manila, Branch X, to stop further proceedings in Civil Case No. 107203-CV. This case stemmed from an ejectment suit filed by Victor Cañeda against the Masinsins. The MTC rendered a judgment ordering the defendants to vacate the premises and pay the plaintiff a monthly compensation until the land is actually vacated. The judgment became final and executory when no appeal was filed. The Masinsins filed a petition for certiorari before the Regional Trial Court (RTC) seeking the annulment of the judgment, but it was dismissed. They then filed a complaint for "Annulment of Judgment, Lease Contract and Damages" before another RTC, but it was also dismissed due to res judicata. Petitioners appealed to the Court of Appeals, but their appeal was denied. The records were remanded to the MTC for execution, and a restraining order was issued by another RTC. However, the petition was dismissed, paving the way for the execution of the judgment. The Masinsins then filed another petition for certiorari, injunction, and declaratory relief before yet another RTC, which issued a restraining order. In the midst of these proceedings, the National Housing Authority proclaimed the property in question as an area for priority development. The Masinsins argued that this proclamation caused the MTC to lose jurisdiction to enforce its decision. The Supreme Court, however, dismissed the petition stating that it lacked merit and strongly censured the petitioners' counsel for engaging in dilatory tactics.

ISSUES:

  1. Whether the Metropolitan Trial Court (MTC) of Manila, Branch X, has lost jurisdiction to enforce its decision in Civil Case No. 107203-CV when the property involved was proclaimed an area for priority development by the National Housing Authority.

  2. Whether the petitioners' repeated filing of complaints and petitions to nullify the MTC decision amounts to an abuse of judicial processes.

RULING:

  1. The MTC of Manila, Branch X, did not lose jurisdiction to enforce its decision in Civil Case No. 107203-CV despite the property in question being proclaimed an area for priority development. The Supreme Court ruled that the property was not for acquisition by the National Housing Authority and the MTC decision can be executed.

  2. The petitioners' repeated filing of complaints and petitions to nullify the MTC decision is considered an abuse of judicial processes. The Supreme Court emphasized that such practice should not be countenanced and warned the petitioners' counsel of record.

PRINCIPLES:

  • Jurisdiction is not lost even when a property is proclaimed an area for priority development if the property is not intended for acquisition by the National Housing Authority.

  • Abusing judicial processes by repeatedly filing complaints and petitions to nullify a final and executory decision is not allowed and can warrant disciplinary action.