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	GR No. 176518 2010-03-02	PARENTS-TEACHERS ASSOCIATION OF ST. MATHEW CHRISTIAN ACADEMY v. METROPOLITAN BANK DEL CASTILLO, J.
It is not necessary to initiate an original action in order for the purchaser at an extrajudicial foreclosure of real property to acquire possession.[21] Even if the application for the writ of possession was denominated as a "petition", it was in substance merely a motion.[22] Indeed, any insignificant lapse in the certification on non-forum shopping filed by the MBTC did not render the writ irregular. After all, no verification and certification on non-forum shopping need be attached to the motion.[23]
	GR No. 171386 2009-07-17	GLORIA R. MOTOS v. REAL BANK QUISUMBING, J.
A petition for the issuance of a writ of possession under Section 7 of Act No. 3135, as amended, is not an ordinary civil action by which one party sues another for the enforcement or protection of a right, or the prevention or redress of a wrong. It is in the nature of an ex parte motion, taken or granted at the instance and for the benefit of one party, without need of notice to or consent by any party who might be adversely affected.[25]