Ngo Bun Tiong v. Sayo
REITERATIONFacts
The Antecedents: Caltex (Phil.) Inc. obtained a decision against Pilares Construction Co. (private respondent) in Civil Case No. 96351, ordering the payment of P67,052.32 plus interests and attorney's fees. The decision became final and executory. A Writ of Execution was issued on August 20, 1976, followed by an Alias Writ of Execution on December 6, 1976. Prior to the alias writ, private respondent filed an "Opposition to the Motion for Writ of Execution" and a "Motion for Reconsideration and To Set Aside Decision," which were denied. A petition for certiorari and mandamus before the Court of Appeals (C.A. G.R. No. SP-05893) was dismissed on October 21, 1976, for failure to show grave abuse of discretion. A petition for review on certiorari of this dismissal was denied by the Supreme Court (L-45443) on January 31, 1977, due to late filing and late payment of fees. Meanwhile, on January 26, 1977, a Certificate of Sale was issued to petitioner Ngo Bun Tiong, the highest bidder at P80,000.00, for properties levied by virtue of the alias writ. Procedural History: Despite the pendency of L-45443 before the Supreme Court, private respondent filed Civil Case No. C-6131 with the Court of First Instance of Rizal, Branch XXXIII, seeking the "Declaration of Nullity of the Auction Sale and Damages." On January 26, 1977, the respondent court issued a temporary restraining order. On February 25, 1977, the respondent court issued the questioned order granting a writ of preliminary prohibitory and mandatory injunction. Petitioner filed a motion for reconsideration, which was declared moot and academic on March 7, 1977, due to petitioner's assurance to return equipment. On the same date, the respondent court declared petitioner in contempt for failing to return the equipment and issued a warrant of arrest. It also declared petitioner and Sheriff Emilio Z. Reyes in default for failure to file a responsive pleading. The instant petition for certiorari and prohibition was filed on March 24, 1977. The Petition: Petitioner seeks the annulment of the February 25, 1977 order and subsequent orders of the respondent court in Civil Case No. C-6131, and prays that the respondent court be ordered to desist from further proceedings.
Issue(s)
Whether a Court of First Instance has jurisdiction to annul or set aside an execution sale conducted by virtue of a decision rendered by another Court of First Instance or a branch thereof, and whether it has jurisdiction to order the return of properties sold at public auction to the judgment debtor, when such sale is based on a final and executory judgment of another court. Whether the issues raised by the private respondent in Civil Case No. C-6131 were already settled by previous rulings of the Court of Appeals and the Supreme Court.
Ruling
The Supreme Court granted the petition, annulling and setting aside the order of respondent court dated February 25, 1977, and all subsequent orders in Civil Case No. C-6131. The temporary restraining order issued by the Supreme Court on March 30, 1977, was made permanent. SO ORDERED.
Ratio Decidendi
On the jurisdiction to annul an execution sale and order the return of properties: The Court held that a Court of First Instance has no jurisdiction to annul or set aside an execution sale conducted by virtue of a decision rendered by another Court of First Instance or a branch thereof. This is based on the principle of judicial stability, which dictates that the judgment of a court of competent jurisdiction may not be interfered with by any court of concurrent jurisdiction. The power to open, modify, or vacate a judgment is restricted to the court in which the judgment was rendered. While the private respondent cited cases allowing annulment of judgments, the Court clarified that the present case sought to set aside an execution sale for alleged irregularities, not the annulment of the final and executory judgment itself. Furthermore, a writ of execution is a matter of right once a judgment becomes final and executory, and a court cannot refuse to issue it except under specific circumstances that render execution unjust, which were not present here. The judgment was considered satisfied upon the issuance of the Certificate of Sale for the full amount of the judgment. On the relitigation of settled issues: The Court found that the allegations and issues raised by the private respondent in Civil Case No. C-6131 were the same issues previously raised in CA-G.R. No. SP-05893 before the Court of Appeals and subsequently in L-45443 before the Supreme Court. Both appellate courts had already ruled adversely against the private respondent. The Court reiterated its stance that the filing of multiple cases over the same issue after an adverse decision constitutes contumacious defiance of court authority and an imposition on the courts, impeding the speedy administration of justice. The principle that litigation must come to an end was emphasized, preventing litigants from having an "unbridled license to come back for another try" after a valid final judgment.
Main Doctrine
A court of first instance has no jurisdiction to annul or set aside an execution sale conducted by virtue of a decision rendered by another court of first instance or a branch thereof, especially when the judgment has become final and executory and the issues raised have already been passed upon by appellate courts. The principle of judicial stability dictates that the judgment of a court of competent jurisdiction may not be interfered with by any court of concurrent jurisdiction.