G.R. No. 154152 ; August 25, 2010
LA CAMPANA DEVELOPMENT CORPORATION, Petitioner, vs. ARTURO LEDESMA, HON. JUDGE ESTRELLA T. ESTRADA, in her capacity as PRESIDING JUDGE, Regional Trial Court, Branch 83, Quezon City, and the HON. COURT OF APPEALS, Respondents.

FACTS

Petitioner La Campana Development Corporation filed an ejectment case against private respondent Arturo Ledesma before the Metropolitan Trial Court (MeTC) for failure to vacate leased premises after the contract’s expiration. Ledesma countered that he had paid rentals and that petitioner’s right to possess the property had been extinguished as the Development Bank of the Philippines (DBP) had foreclosed on and taken possession of the property since 1997. The MeTC ruled for petitioner, ordering Ledesma to surrender possession. Ledesma appealed to the Regional Trial Court (RTC), filing a supersedeas bond to stay execution. The RTC affirmed the MeTC judgment, and petitioner moved for and was granted immediate execution.
Ledesma elevated the case to the Court of Appeals (CA) via a petition for review, praying for a temporary restraining order or preliminary injunction. The CA issued a temporary restraining order and subsequently a writ of preliminary injunction via its February 13, 2002 Resolution. The CA justified the injunction, noting that DBP was the established owner per a final CA ruling, and only the owner or its derivative rights holder could lawfully eject a tenant. It found that petitioner’s title had been conveyed to DBP during the lease, making the rule on tenant estoppel inapplicable.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in issuing the writ of preliminary injunction to stay the execution of the RTC judgment in the ejectment case.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the CA. Grave abuse of discretion implies a capricious, whimsical, or despotic exercise of judgment equivalent to lack of jurisdiction, which petitioner failed to demonstrate. While Section 21, Rule 70 of the Rules of Court states that an RTC judgment in an ejectment case is immediately executory, the Court has consistently held, as in Benedicto v. Court of Appeals, that appellate courts may stay execution via preliminary injunction if circumstances so require. This is particularly equitable where the plaintiff’s right to recover possession is seriously contested in a proper proceeding, as here, where ownership had been transferred to DBP during the lease.
Furthermore, the CA correctly considered the supersedeas bond filed in the MeTC as sufficient for the injunction. In unlawful detainer, recoverable damages are limited to rent or fair rental value for loss of use. The supersedeas bond answers precisely for such unpaid rentals, making it an adequate bond for the injunction’s purpose. Therefore, the CA acted within its sound discretion, and there was no basis to compel immediate execution of the RTC judgment.