Tuason v. Torres
REITERATIONFacts
The Antecedents: Prior to 1953, the Deudors and their vendees, along with the Tuasons, were involved in five cases disputing the ownership and possession of approximately 50 quiñones of land in Tatalon, Quezon City. On March 16, 1953, the parties entered into a COMPROMISE AGREEMENT, wherein the Deudors and their vendees recognized the Tuasons' ownership and agreed to vacate and deliver the land for a consideration of P1,201,063.00. This agreement was approved by the Court of First Instance of Rizal, Branch IV, on April 10, 1953, and the decision became final and executory. Procedural History: Despite the final decision, not all of the land was delivered. The Tuasons sought enforcement, and the Deudors were given four months to deliver the remaining 30 quiñones, a ruling upheld by the Supreme Court. The Deudors and their vendees subsequently filed Civil Case No. 49657 to annul the compromise agreement, alleging fraud, which was dismissed for improper venue and lack of cause of action. Undeterred, the Deudors filed Civil Case No. 8080 to recover land and annul titles. Later, on January 18, 1965, Branch II of the Court of First Instance of Quezon City declared the Tuasons' titles null and void. Subsequently, on February 11, 1965, respondents Fulgencio and other Deudor vendees filed Civil Case No. 8559 in the Court of First Instance of Pasig, seeking to be declared owners, annul the decision of April 10, 1953, compel vacation and accounting, and declare Tuasons' titles void. The Tuasons moved to dismiss Civil Case No. 8559, arguing lack of jurisdiction of the Pasig court to annul a decision of a co-equal branch. The motion was denied, and preliminary injunctions were issued. The Tuasons then filed a petition for certiorari and prohibition with the Supreme Court. The Petition: The Tuasons sought to prevent the Court of First Instance of Pasig from acting in Civil Case No. 8559, arguing that only the branch that rendered the decision could annul it.
Issue(s)
Whether the Court of First Instance of Pasig has the jurisdiction to annul and enjoin the execution of a final decision rendered by a co-equal branch of the Court of First Instance of Quezon City. Whether the compromise agreement and the decision approving it are valid and binding.
Ruling
The petition for certiorari and prohibition is granted. The Court of First Instance of Rizal, sitting at Pasig, is ordered to permanently desist from taking cognizance of, and acting in, its Civil Case No. 8559. The preliminary injunction heretofore issued is made permanent.
Ratio Decidendi
On the jurisdiction of the Court of First Instance of Pasig to annul a decision of a co-equal branch: The Supreme Court held that the petitioner's submission that only the branch that rendered a decision can annul its own judgment is well-taken. It is a settled principle that the jurisdiction to annul a judgment of a branch of the Court of First Instance belongs solely to the same branch that rendered the judgment. Any other branch, even within the same judicial district, that attempts to do so either exceeds its jurisdiction or acts with grave abuse of discretion amounting to lack of jurisdiction. In such instances, certiorari and prohibition are proper remedies to prevent the attempting branch from proceeding to nullify a final decision rendered by a co-equal and coordinate branch. The Court cited Cabigao v. Del Rosario and P.N.B. v. Javellana, which were reaffirmed in Mas v. Dumaraog, as precedents for this principle. Therefore, the Court of First Instance of Pasig acted without or in excess of its jurisdiction when it entertained Civil Case No. 8559, which sought to annul a final decision of the Court of First Instance of Quezon City. On the validity of the compromise agreement and the decision: The Court found no need for Civil Case No. 8559 to pend further. The respondents' bases for seeking to nullify the decision of the Court of First Instance of Quezon City were the alleged total rescission of the compromise agreement and the alleged nullity of the Tuasons' titles. However, the Supreme Court had previously settled in related cases involving the Tuasons and the Deudors that only the obligation of the Tuasons to make further payments under the compromise agreement had been rescinded; the rest of the agreement remained valid and binding between the parties. Regarding the alleged nullity of the Tuasons' titles, the Court noted that the basis of the April 10, 1953 decision was not the Tuasons' titles themselves, but the COMPROMISE AGREEMENT wherein the Deudors and respondents acknowledged the complete, absolute, and indefeasible titles of the Tuasons. The validity of the titles, if disputed, should be resolved in appropriate proceedings, but this did not affect the validity of the compromise agreement and the decision based upon it.
Main Doctrine
A court of first instance cannot annul or enjoin the execution of a final decision rendered by a co-equal and coordinate branch of the same court; such an act constitutes either an excess of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction, warranting certiorari and prohibition.