Spouses Godfrey v. Integrated Credit & Corporate Services

Summary

This case involved spouses Teves who lost their property through extrajudicial foreclosure to ICCS, later transferred to Carol Aqui. The main issue was whether the trial court could order collection of back rentals in a writ of possession proceeding. The Supreme Court ruled that once the redemption period expired, the foreclosure buyer became absolute owner entitled to all fruits of the property, including rentals collected by the former owners. The Court held that trial courts have auxiliary jurisdiction under Section 6, Rule 135 to grant relief necessary to carry their jurisdiction into effect, even in land registration proceedings. The Court also confirmed that Presidential Decree 1529 eliminated the jurisdictional distinction between land registration and ordinary civil courts. The decision established that former property owners cannot retain rental income after losing ownership through foreclosure, and courts can address such unjust enrichment in writ of possession proceedings.