Trinidad v. Cabrera
REITERATIONFacts
The Antecedents: Petitioners, Spouses Benito and Soledad Trinidad, filed an ejectment case against respondents, Spouses Luis and Delia Cabrera, before the Metropolitan Trial Court (MeTC) of Quezon City. The MeTC ruled in favor of the Trinidads, ordering the Cabreras to vacate the premises, pay rentals in arrears, and pay for the use and occupancy of the premises, attorney's fees, and costs. Procedural History: The Regional Trial Court (RTC) affirmed the MeTC decision. The Court of Appeals dismissed the Cabreras' petition for review. The Supreme Court denied their petition for certiorari (G.R. No. 95128) for failure to show reversible error by the Court of Appeals. Entry of judgment was made on January 31, 1991. The Petition: The Trinidads sought execution of the MeTC decision. The Cabreras filed a petition for injunction with restraining order before the RTC, seeking to stop the MeTC judge from enforcing the decision, alleging that their motion for reconsideration in the Supreme Court was still pending "without action" and thus the execution was premature. RTC Judge Jose M. Aguila granted the injunction, reasoning that the Supreme Court's "noted without action" resolution on the motion for reconsideration meant it was still pending and the entry of judgment was premature. The Trinidads filed a petition for certiorari with the Supreme Court assailing Judge Aguila's decision.
Issue(s)
Whether respondent Judge Jose M. Aguila gravely abused his discretion in issuing the injunction. Whether the Supreme Court's entry of judgment in G.R. No. 95128 was premature.
Ruling
The petition for certiorari is GRANTED. The Decision dated June 25, 1991 of respondent Judge Jose M. Aguila in Civil Case No. Q-91-9005 is annulled and set aside. The Metropolitan Trial Court of Quezon City, Branch 32, is ordered to execute without further delay its final and executory decision in Civil Case No. XXXII-0560. This decision is immediately executory.
Ratio Decidendi
On whether respondent Judge Jose M. Aguila gravely abused his discretion in issuing the injunction: The Supreme Court held that Judge Aguila gravely abused his discretion by issuing the injunction. As a subordinate court, his duty was to execute and implement the final decisions of the Supreme Court, not to impede them. By holding that the Supreme Court's entry of judgment was premature, Judge Aguila overstepped the limits of his authority. He should have refrained from sitting in judgment upon the action of the Supreme Court. If the Cabreras believed the entry of judgment was premature, they should have filed a motion to set it aside in the Supreme Court, not attack it in a lower court. On whether the Supreme Court's entry of judgment in G.R. No. 95128 was premature: The Supreme Court found Judge Aguila's opinion that the entry of judgment was premature to be erroneous. The motion for reconsideration filed by Attorney Dapucanta was filed by a lawyer who had no standing before the Court, as his appearance was "not filed in accordance with the Rules." Therefore, the motion was a sham pleading and did not interrupt the period for the finality of the Court's resolution dismissing the petition for review. The Supreme Court's resolution noting the withdrawal of the original counsel and noting without action the motion for reconsideration did not mean the motion remained pending for resolution. The entry of judgment was therefore not premature.
Main Doctrine
A subordinate court commits grave abuse of discretion when it enjoins the enforcement of a Supreme Court decision or writ of execution based on an erroneous belief that the Supreme Court's entry of judgment is premature. Such a challenge should be filed before the Supreme Court itself.