Nique v. Zapatos
REITERATIONFacts
The Antecedents: Complainant Licerio Nique was the plaintiff in an ejectment case (Civil Case No. 300) for Forcible Entry with Restraining Order and Writ of Preliminary Injunction concerning a fishpond. Initially, the MTCC of Tangub City, under Judge Ricardo L. Salvanera, ordered the defendants to vacate and restore possession to the plaintiff. Subsequently, Judge Salvanera lifted the restraining order and delivered possession to the defendants, which was later affirmed by his denial of the plaintiff's motion for reconsideration. Procedural History: The plaintiff filed a petition for certiorari in the Court of Appeals, which referred the case to the Regional Trial Court (RTC), Branch XIV, Tangub City. The RTC set aside Judge Salvanera's orders and directed him to reinstate the Writ of Preliminary Mandatory Injunction and restore the plaintiff to possession. After this decision became final and executory, the plaintiff filed a motion for execution in the trial court, which was then presided over by Judge Felipe G. Zapatos. The Petition: Judge Zapatos denied the plaintiff's motion for execution and dissolved the writ of preliminary mandatory injunction ordered reinstated by the RTC. The plaintiff filed an administrative complaint against Judge Zapatos for gross ignorance of the law, failure to perform a directed act, causing delay and damages, and giving undue advantage to the defendants.
Issue(s)
Whether respondent Judge Zapatos committed gross ignorance of the law and disobedience of a final judgment of a superior court by denying the motion for execution and dissolving the writ of preliminary mandatory injunction. Whether the alleged change in the situation of the parties justified the dissolution of the injunction.
Ruling
The Court finds respondent MTCC Judge Felipe G. Zapatos GUILTY of disobedience of a final judgment of a superior court, and of obstructing the administration of justice. He is ordered to pay a fine of P1,000.00 and warned against future misfeasance.
Ratio Decidendi
On the issue of gross ignorance of the law and disobedience of a final judgment: Respondent Judge Zapatos ought to know his place in the judicial hierarchy. Occupying a court lower in rank than the RTC, he owes respect to the latter and is bound by its disposition or decision. His act of "reversing" the final judgment of the RTC, instead of complying with his mandatory and ministerial duty of executing the same, constitutes audacity, arrogance, and presumption. If the RTC's decision was unacceptable to the defendants, their remedy was to appeal to a higher court; failing that, they, along with the lower court, were bound by the judgment. The execution of a final judgment is a ministerial duty of the trial court, and a lower court cannot disregard or disobey with impunity a final judgment or order of a higher court. The appellate jurisdiction of a higher court would be rendered meaningless if lower courts could disregard its final judgments. On whether the alleged change in the situation of the parties justified the dissolution of the injunction: The alleged "change in the situation of the parties," such as the defendants' investment of P2 million and their filing of a P60,000.00 counterbond, did not justify defying the decision of the appellate (RTC) court. The alleged P2-million investment may have been made during the defendants' occupation of the fishpond as a result of Judge Salvanera's order lifting the restraining order. The defendants' offer to post a counterbond twice the amount of the plaintiff's bond was not a sufficient justification for disobeying the RTC's decision. A municipal trial judge must defer to orders of higher courts regardless of personal opinion, as "a becoming modesty of inferior courts demands realization of the position that they occupy in the interrelation and operation of the integrated judicial system of the nation."
Main Doctrine
A municipal trial judge, occupying a court lower in rank than the Regional Trial Court, owes respect to the latter and is bound by its disposition or decision. The execution of a final judgment is a ministerial duty, and a lower court cannot disregard or disobey with impunity a final judgment or order of a higher court.