Vergara v. Rugue
REITERATIONFacts
The Antecedents: Abraham Rugue filed a case for annulment of sale and specific performance against Alfonso Vergara and others, seeking to annul the sale of Lot No. 9, Block No. 12 of the Tuason Estate to Vergara and to compel the Land Tenure Administration (LTA) to execute a deed of sale in his favor. Rugue had a contract of sale with Kapisanan "Ang Buhay, Inc." for the lot and had paid the installments. However, Vergara intervened, claiming a preferential right. The LTA initially awarded the contract to Rugue, but the Office of the President, through Executive Secretaries Pajo and Castillo, reversed this decision and awarded the contract to Vergara, reserving Rugue's right to reimbursement. Procedural History: The trial court dismissed Rugue's complaint but ordered the LTA to refund Rugue's payments and reimburse him for improvements. On appeal, the Court of Appeals reversed the trial court's decision, canceling the sale to Vergara and ordering him to reconvey the lot to Rugue. Vergara filed a petition for relief from judgment with the Court of Appeals, alleging mistake of counsel, which was denied. He then filed a petition for review by certiorari with the Supreme Court (G.R. No. L-32309), which was also denied. Subsequently, Rugue moved for execution of the Court of Appeals' decision, which was granted by the trial court. Vergara then filed the present petition for prohibition with mandatory injunction to restrain the enforcement of the execution order, alleging grave abuse of discretion and excess of jurisdiction by the Court of Appeals. The Petition: Petitioner Alfonso Vergara sought to restrain respondent Judge Jose S. dela Cruz, the Sheriff of Manila, and the Register of Deeds of Manila from enforcing the order of execution of the Court of Appeals' decision. He also prayed to be declared the rightful owner of the lot and for damages from Abraham Rugue. Vergara argued that the Court of Appeals committed grave abuse of discretion by collaterally attacking a final decision of the Office of the President, rendering a decision based on misstated facts, honoring a void sale to Rugue, and rendering a decision contrary to the issues raised on appeal.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion or acted in excess of jurisdiction in reversing the trial court's decision and ordering the reconveyance of the lot to Abraham Rugue. Whether the doctrine of res judicata bars the relitigation of issues already decided by the Supreme Court in a prior petition. Whether the remedy of prohibition is proper to restrain the enforcement of an order of execution based on alleged errors of judgment.
Ruling
The petition for prohibition is DISMISSED. Costs against the petitioner. The Court held that the issues raised by petitioner Vergara had already been passed upon and resolved with finality by the Supreme Court in G.R. No. L-32309, which denied his petition for review by certiorari. Therefore, relitigation of these issues is barred by the doctrine of res judicata. The Court also emphasized that prohibition is a remedy to prevent unlawful exercise of authority and not to correct errors of judgment or to prevent the enforcement of an erroneous judgment when the court acted within its jurisdiction.
Ratio Decidendi
On the issue of grave abuse of discretion and excess of jurisdiction by the Court of Appeals: The Court found no grave abuse of discretion or excess of jurisdiction on the part of the Court of Appeals. Petitioner's argument that the Court of Appeals exceeded its appellate jurisdiction by setting aside the decision of the Executive Secretary was deemed legally untenable. The Court noted that the defense of res judicata was never raised by the petitioner in the lower court or in his appeal to the Court of Appeals, nor was the jurisdiction of the Court of Appeals questioned in his prior petition for certiorari with the Supreme Court. The petitioner had, in fact, invoked the Supreme Court's review based on the alleged departure from usual judicial proceedings, not on lack of jurisdiction. The Court reiterated that it is too late for the petitioner to question the jurisdiction of the Court of Appeals on the ground of res judicata, as the defense of res judicata, if not interposed, is deemed waived. Furthermore, the Executive Secretary was a party-defendant, and the validity of his decisions was squarely put in issue, allowing the Court of Appeals to pass upon the decision of the Executive Secretary to ascertain if it was supported by substantial evidence or if the administrative officer acted with gross abuse of discretion, fraud, or error of law. On the applicability of the doctrine of res judicata: The Court held that the doctrine of res judicata had already set in, not only due to the finality of the Court of Appeals' decision but also due to the Supreme Court's resolution in G.R. No. L-32309, which sustained the Court of Appeals' decision. The Court explained that res judicata bars the relitigation of material facts or questions that were in issue and adjudicated in a former action, or were necessarily involved in the final judgment. The petitioner could not relitigate anew the questions of fact and law that were raised and resolved in the Court of First Instance and the Court of Appeals, and subsequently affirmed by the Supreme Court. The Court cited previous rulings emphasizing that a judgment is conclusive on all points directly involved and necessarily determined, and that facts settled and adjudicated in a former proceeding cannot be relitigated. On the propriety of the remedy of prohibition: The Court reiterated that the office of the extraordinary remedy of prohibition is to prevent the unlawful and oppressive exercise of legal authority and to restrain usurpation by inferior tribunals, not to correct errors of judgment. It is a preventive remedy, not intended to provide a remedy for acts already accomplished or to correct errors in procedure or erroneous decisions. The writ of prohibition will lie only to prevent an encroachment, excess, usurpation, or improper assumption of jurisdiction, or when there is no adequate remedy by appeal or other prescribed methods of review. In this case, the petitioner was attempting to relitigate issues that had already been decided with finality, and the Court of Appeals had acted within its jurisdiction in rendering its decision. Therefore, prohibition was not the proper remedy.
Main Doctrine
A petition for prohibition to restrain the enforcement of an order of execution will not prosper if the issues raised have already been passed upon and resolved with finality by the Supreme Court in a prior petition for certiorari, as such relitigation is barred by the doctrine of res judicata. Furthermore, the remedy of prohibition is not available to correct errors of judgment or to prevent the enforcement of an erroneous judgment if the court acted within its jurisdiction.