JUAN ENRIQUEZ v. CA

FACTS:

This case involves an unlawful detainer case filed by private respondents against petitioners. The Metropolitan Trial Court (MTC) rendered a decision in favor of private respondents, ordering petitioners to vacate the premises, restore it to private respondents, and pay the necessary fees and costs. Petitioners failed to enforce the judgment within the five-year period. They filed an action to revive the judgment, but petitioners argued that private respondents were not the owners of the land subject to the unlawful detainer case and that changes in the parties' relationship rendered enforcement of the judgment unjust. The MTC denied petitioners' motion to dismiss and motion for reconsideration. Petitioners elevated the case to the Regional Trial Court (RTC) by way of a special civil action for certiorari. However, the RTC dismissed the action. The MTC eventually rendered a decision directing the enforcement of the judgment. Petitioners appealed to the RTC, which affirmed the MTC's decision. The Court of Appeals denied petitioners' petition for review.

ISSUES:

  1. Whether private respondents had to prove the enforceability of the judgment to revive it.

  2. Whether non-ownership by private respondents is a valid defense in an action to revive judgment.

RULING:

  1. The Supreme Court affirmed the decision of the Court of Appeals.

PRINCIPLES:

  • An action to revive judgment only requires proof of a final judgment that is not yet prescribed and has remained unexecuted after the lapse of five (5) years but not more than ten (10) years from its finality. Proof of the enforceability of the judgment is not necessary.

  • An action to revive judgment does not retry the merits of the original action. Its cause of action is the judgment itself, and not the merits of the case.

  • Non-ownership by private respondents is not a valid defense in an action to revive judgment. The ownership issue pertains to the merits of the original case, which has already been decided with finality.