Bukidnon Doctors' Hospital v. Metropolitan Bank & Trust Co.

Summary

The Supreme Court reversed the RTC's grant of a writ of possession, establishing that when a mortgagee-turned-owner enters into a lease agreement with the mortgagor after foreclosure and title consolidation, the proper remedy for eviction is ejectment or unlawful detainer, not a writ of possession. The Court held that the lease agreement created a new contractual relationship governed by lease law rather than foreclosure law. Since the bank was already in material possession through the lease arrangement and accepting rental payments, and the hospital was a legitimate possessor as lessee under Civil Code Article 525, an ex parte writ of possession was improper. This decision provides important guidance on the intersection between foreclosure remedies and subsequent landlord-tenant relationships, clarifying that different legal relationships require different remedies under Philippine law.