Mangayao v. Lasud
REITERATIONFacts
The Antecedents: Petitioners, non-Christian Filipinos of the Subano tribe, filed an action for recovery of property and declaration of nullity of contract against private respondents. They obtained a favorable judgment in the Court of First Instance, which was affirmed on appeal by the Supreme Court. This decision became final and executory. Procedural History: Petitioners were placed in possession of the property, and private respondents were reimbursed. Subsequently, private respondents filed an action for annulment of the judgment, despite its finality. Respondent Judge issued an order restraining petitioners from executing the Supreme Court's decision. The Petition: Petitioners filed a certiorari proceeding, arguing that the respondent Judge acted with jurisdictional infirmity in restraining the execution of a final and executory judgment of the Supreme Court.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion amounting to lack of jurisdiction in issuing an order restraining the execution of a final and executory judgment of the Supreme Court. Whether the doctrine of the law of the case was violated by the respondent Judge's actuation.
Ruling
The Supreme Court granted the writ of certiorari, nullified and set aside the order of the lower court restraining the execution of the judgment, and made permanent the writ of preliminary injunction issued by the Supreme Court. The respondent Judge was directed to dismiss the annulment case filed by the private respondents.
Ratio Decidendi
On the issue of jurisdictional infirmity and the law of the case: The Court held that the respondent Judge committed a jurisdictional infirmity and a grave abuse of discretion by restraining the execution of a judgment that had become final and executory, especially one affirmed by the Supreme Court. The doctrine of the law of the case dictates that a decision of the Supreme Court, once final, is binding on all inferior courts and cannot be altered or modified by them. The respondent Judge's receptivity to an action seeking to thwart a Supreme Court judgment was deemed surprising and unwarranted. The Court cited numerous cases, including Kabigting v. Acting Director of Prisons, Compagnie Franco-Indochinoise v. Deutsche-Australische Dampschiffs Gesellschaft, People v. Olarte, and Sanchez v. Court of Industrial Relations, to underscore the finality and binding effect of Supreme Court decisions on lower courts. The respondent Judge's actions were considered inexplicable and unjustifiable, failing to abide by a final decision of the Supreme Court. On the policy of protecting non-Christian Filipinos: The Court further emphasized that the respondent Judge failed to consider the clear policy of the law, as articulated in Mangayao v. Lasud itself, which protects illiterate non-Christians from exploitation. The law requires the approval of authorities for deeds of sale by illiterate non-Christians, and unapproved conveyances are considered void ab initio. The Court reiterated the intent of the statutes to guard the patrimony of illiterate non-Christians from those who prey upon their ignorance. This protective policy, aligned with the principle of social justice, further supported the petition. The Court invoked the aphorism that "he who has less in life should have more in law," highlighting the constitutional mandate to promote social justice.
Main Doctrine
A respondent judge commits grave abuse of discretion and acts without or in excess of jurisdiction when they issue an order restraining the execution of a judgment that has become final and executory, especially when such judgment was affirmed by the Supreme Court. This is in clear violation of the doctrine of the law of the case, which mandates that decisions of the Supreme Court, once final, are binding on all inferior courts and beyond their power to alter or modify.