De Guzman

Summary

This case involves a dispute over a property sold at public auction for tax delinquency. Petitioners De Guzman were the original owners whose property was sold to respondent Chico at a tax auction. After the redemption period expired, respondent obtained a new certificate of title and filed an ex parte petition for a writ of possession. Petitioners challenged this, arguing that a certificate against forum shopping was required and that the proceedings should have been in the nature of an accion reivindicatoria rather than a summary ex parte petition. The Supreme Court ruled that no certificate against forum shopping is required for ex parte petitions for writs of possession since they are not initiatory pleadings but merely incidents in the transfer of title. The Court affirmed respondent's right to possession as an incident of her ownership acquired through the tax sale, emphasizing that the previous judgment establishing her ownership had become final and executory.