Doliente v. Blanco
REITERATIONFacts
The Antecedents: Natividad Doliente filed a case to quiet title over two parcels of land and recover damages against Jacinto Doliente and Federico Doliente. The trial court absolved the defendants. The Court of Appeals affirmed this decision with costs against the plaintiff. Procedural History: After the case was returned to the lower court, the defendants moved for execution of the judgment and to require the plaintiff to render an accounting of the products gathered from one of the lots she possessed since January 1946. The respondent judge issued orders directing the plaintiff to surrender possession of the lots, pay costs, and render an accounting of products from February 20, 1948. The plaintiff's motion for reconsideration was denied. Subsequently, the respondent judge ordered the plaintiff to deliver 57 ½ bultos of palay or its value (P1,497.50) with legal interest. The Petition: The plaintiff filed a petition for certiorari with mandatory injunction, seeking to nullify the respondent judge's orders dated October 27, 1949, and November 18, 1949, alleging they were issued in excess of jurisdiction.
Issue(s)
Whether the respondent judge acted legally and within his jurisdiction in issuing the orders of October 27, 1949, and November 18, 1949, requiring the plaintiff to render an accounting of products and to pay damages. Whether the defendants could still claim damages after the decision of the Court of Appeals became final and executory, despite no award of damages being made in the said decision.
Ruling
The petition is granted. The Court declares the orders of the respondent judge dated October 27, 1949, and November 18, 1949, null and void and enjoins him from enforcing them.
Ratio Decidendi
On the issue of the respondent judge's jurisdiction in issuing the questioned orders: The Supreme Court held that the respondent judge acted in excess of his jurisdiction, if not with abuse of authority. The orders requiring the plaintiff to render an accounting and to pay damages were issued after the decision of the Court of Appeals had become final and executory. This decision affirmed the lower court's ruling which absolved the defendants without any award of damages. The Court emphasized the well-known doctrine that when a judgment of a higher court is returned to a lower court, the latter's function is merely ministerial – to issue the order of execution according to the terms of the judgment. The lower court cannot amend the judgment, add new reliefs, or review matters already decided on appeal. The Court cited Shioji vs. Harvey and Sibbald vs. United States to support the principle that an inferior court is bound by the decree of a superior court and must carry it into execution without variation. On the defendants' claim for damages: The Court found no merit in the respondents' claim that the plaintiff could still be held answerable for damages due to a bond posted earlier. While the plaintiff had posted a bond for P500 through the Philippine Guaranty Company, the terms of the bond clearly indicated that it was to answer for damages if and when they were awarded by the appellate court. Since neither the lower court nor the Court of Appeals awarded any damages in their decisions, the defendants' claim for damages was deemed devoid of merit. The Court stated that it was the duty of the defendants to establish their claim for damages during the trial, and having failed to do so, they could not claim damages at this late stage. The decision of the court had already become final, and proving damages then was considered too late.
Main Doctrine
A lower court, upon remand of a case with a final and executory decision from a higher court, has only the ministerial duty to issue the writ of execution according to the terms of the judgment. It cannot amend the judgment, add new reliefs, or review matters already decided by the appellate court.