Rosensons, Inc. v. Jimenez
REITERATIONFacts
1. The Antecedents: Rosensons, Inc., the owner of a building and lot in Malate, Manila, leased the premises to Go Yit on a month-to-month basis. Go Yit converted the building into the Miami Hotel. For failing to pay the P8,000.00 monthly rental for September 1974, Rosensons, Inc. filed an ejectment suit against Go Yit before the City Court of Manila. The City Court ruled in favor of Rosensons, Inc., ordering Go Yit to vacate the premises and pay significant arrears and future rentals. 2. Procedural History: Following the City Court's judgment, a writ of execution was issued. When the sheriff attempted to enforce the writ, Ng Che, an employee of the Miami Hotel, intervened, claiming to be the court-appointed receiver of the partnership operating the hotel by order of the Court of First Instance of Manila in Civil Case No. 77959. Despite this claim, Ng Che was ordered to vacate. Subsequently, Ng Che filed a complaint for damages and sought an injunction in Civil Case No. 96129, which was denied. However, in Civil Case No. 77959, the respondent court issued orders directing Ng Che to continue as receiver, restraining the sheriffs, and ordering Rosensons, Inc. to cease demolition and provide hotel access. Rosensons, Inc.'s motion to lift these orders was denied, and a further order compelled them to open a specific room. 3. The Petition: Rosensons, Inc. filed a petition for certiorari and prohibition with preliminary injunction, seeking to annul the orders issued by the respondent court in Civil Case No. 77959. They argued that the respondent court lacked jurisdiction to issue these orders, which effectively nullified a final and executory judgment from the City Court. Petitioners also asserted that enforcement of the orders would cause irreparable damage due to their plans to construct a condominium by June 1976. They claimed there was no other plain, speedy, and adequate remedy at law.
Issue(s)
Whether the Court of First Instance (CFI) committed grave abuse of discretion or acted without jurisdiction in issuing orders that restrained the execution of a final judgment rendered by the City Court in an ejectment suit.
Ruling
The petition is granted. The orders issued by the Court of First Instance of Manila on December 20, 1974, and March 6, 1975, in Civil Case No. 77959, insofar as they conflict with the decision rendered by the City Court of Manila in Civil Case No. 236389, are annulled and set aside. The temporary restraining order is made permanent. Costs against respondents Lee Sai and Ng Che.
Ratio Decidendi
On Issue 1: The Court ruled that the orders issued by the respondent judge were improperly issued because they constituted an unlawful collateral attack on a final and executory judgment. Under the rules of procedure, the validity of a final judgment can only be attacked through a direct action for annulment or by demonstrating a total lack of jurisdiction in a motion. In this case, there was no showing or even an allegation that the City Court of Manila lacked jurisdiction to render the judgment of ejectment against Go Yit. By ordering the receiver (Ng Che) to continue managing the hotel and restraining the owners from demolition, the Court of First Instance (CFI) effectively nullified the City Court's final decision. The Supreme Court emphasized that while a stay of execution may be authorized to serve the ends of justice, it cannot be used to 'set at naught' a final judgment or make a mockery of the justice system. Applying the precedent in Reyes vs. Barreto-Datu (94 Phil. 446), the Court held that without a showing of lack of jurisdiction, the final judgment of the City Court must be respected and cannot be interfered with by a court of coordinate jurisdiction.
Main Doctrine
Orders issued by a court that interfere with or seek to set at naught a final and executory judgment of another court, where there is no showing that the latter court lacked jurisdiction, are improperly issued and may be annulled.