Paper Industries Corporation of the Philippines v. Honorable Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioner Paper Industries Corporation of the Philippines (PICOP) obtained a favorable judgment against private respondent Vicmar Development Corporation (Vicmar) for P3,462,470.75 plus interest and attorney's fees. Vicmar paid the principal but not the interest and attorney's fees, claiming waiver. The trial court (Branch 145, Madayag court) agreed with PICOP that there was no waiver, and a writ of execution was issued for the unpaid P257,091.82. Procedural History: The sheriff levied on Vicmar's machineries, equipment, real properties, and logs. Vicmar filed Civil Case No. 9301 before Branch 132 (Tamayo court) to nullify the sheriff's proceedings and sought a preliminary injunction. The Tamayo court issued a restraining order. PICOP filed a motion for an alias writ of execution before the Madayag court, which was granted. Vicmar obtained another restraining order from the Tamayo court. PICOP's motion to dismiss Civil Case No. 9301 for lack of jurisdiction was denied by the Tamayo court. This denial was affirmed by the Intermediate Appellate Court (IAC). The Petition: PICOP questions the jurisdiction of the Tamayo court (Branch 132) to issue restraining orders and nullify the execution proceedings of the Madayag court (Branch 145), arguing that they are coordinate and co-equal courts.
Issue(s)
Whether Branch 132 of the Regional Trial Court of Makati, as a coordinate and co-equal court, had the power to restrain the execution of the judgment of Branch 145 of the same court, considering the principle of non-interference between coordinate courts and the jurisdiction of the issuing court over execution proceedings. Whether the Tamayo court (Branch 132) acquired jurisdiction over Civil Case No. 9301 to annul the sheriff's proceedings in Civil Case No. 3963 of the Madayag court (Branch 145), considering the nature of Civil Case No. 9301, the control over ministerial officers, and the arguments regarding the 'dead writ'.
Ruling
The petition is GRANTED. The questioned decision of the Intermediate Appellate Court is REVERSED and SET ASIDE. Branch 132 of the Makati Regional Trial Court is declared without jurisdiction over Civil Case No. 9301, except to DISMISS the same. The temporary restraining order issued on July 29, 1985, is made PERMANENT.
Ratio Decidendi
On the issue of jurisdiction of coordinate courts and execution proceedings: The Supreme Court reiterated the principle that a court rendering a final judgment retains jurisdiction for its execution, excluding other coordinate courts. Civil Case No. 9301, though captioned as an action for damages, was essentially an attempt to nullify the execution proceedings in Civil Case No. 3963. Deputy Sheriff Nequinto, restrained by the Tamayo court, was a ministerial officer of the Madayag court, under its control. The Tamayo court lacked jurisdiction over him. Any irregularities in execution, like enforcing a 'dead writ,' must be litigated in the Madayag court. Coordinate courts cannot interfere with each other's cases, orders, or judgments, especially through injunctions. On the nature of Civil Case No. 9301 and the 'dead writ' argument: The argument that the writ was 'dead' and the subsequent levy was void should have been addressed by the Madayag court, which had exclusive jurisdiction. The IAC's ruling was based on an incorrect premise. The court that issued the writ retains supervisory control over its execution, including determining all questions of fact and law involved. Challenges to the levy or execution should have been filed before the Madayag court. The Tamayo court's assumption of jurisdiction and issuance of restraining orders constituted a grave abuse of discretion, interfering with the Madayag court's exclusive jurisdiction.
Main Doctrine
A court which has rendered a final and executory judgment retains jurisdiction over its judgment for its execution and all incidents thereof, to the exclusion of all other coordinate courts. Alleged irregularities in the execution of a judgment must be litigated in the court that issued the writ of execution.