People v. Court of Appeals
REITERATIONFacts
The Antecedents: The Roman Catholic Bishop of Malolos, Inc. (RCBM) owned a 118-hectare fishpond leased to L.K. Trading, Inc. (private respondent). Bishop Cirilo Almario renewed the lease for L.K. Trading despite being informed by Cofradia Nuestra Señora Dela Correa (petitioners) of its intent to take over administration after the lease expired. Petitioners filed a complaint for nullity of title, sum of money, accounting, and damages against RCBM and Bishop Almario. Procedural History: The trial court issued a temporary restraining order and later a writ of preliminary injunction enjoining RCBM and Bishop Almario from executing a new lease and exercising acts of ownership. Intervenors L.K. Trading and the legally incorporated Cofradia Nuestra Señora Dela Correa, Inc. were allowed to intervene. The trial court issued an order directing defendants to desist from disturbing petitioners in their operation of the fishpond, but ordered petitioners not to harvest fish without informing the court. Subsequently, petitioners, with the deputy sheriff and constabulary, forcibly entered the fishpond. L.K. Trading and Bishop Almario filed motions for reconsideration. L.K. Trading then filed a Petition for Certiorari and Prohibition with the Court of Appeals, which granted a temporary restraining order. On April 11, 1991, the Court of Appeals set aside the trial court's orders, ordered petitioners to desist from taking possession until ownership was adjudicated, and remanded the case for re-raffle and trial. The Petition: Petitioners filed a Petition for Review with the Supreme Court, which was denied for lack of merit. Subsequently, L.K. Trading filed a Motion to Direct Immediate Execution of Judgment, assailing trial court orders dated February 14, 1992, August 11, 1992, and September 30, 1992. These orders, issued during the execution stage, allowed an intervenor, Rodrigo Bagtas (lessee of petitioners), to retain possession of the fishpond, thereby contravening the final and executory decision of the Court of Appeals. The Supreme Court issued a Temporary Restraining Order and subsequently made it permanent, setting aside the questioned trial court orders and directing the trial court to issue a writ of execution consistent with the Court of Appeals' decision.
Issue(s)
Whether the trial court committed grave abuse of discretion amounting to lack of jurisdiction in issuing orders that contravened a final and executory decision of the Court of Appeals. Whether intervention is permissible during the execution stage after a judgment has become final and executory.
Ruling
The Supreme Court resolved to set aside the orders of the trial court dated February 14, 1992, August 11, 1992, and September 30, 1992, to the extent that they are inconsistent with the Decision of the Court of Appeals dated April 11, 1991, as affirmed by the Supreme Court. The Temporary Restraining Order dated November 23, 1992, was made permanent. The Regional Trial Court was directed to issue immediately a writ of execution consistent with and precisely implementing the Court of Appeals' decision.
Ratio Decidendi
On the issue of grave abuse of discretion and contravention of a final and executory decision: The Court held that the trial court committed a clear and grave abuse of discretion amounting to lack of jurisdiction. The orders issued by the trial court, particularly those allowing intervenor Rodrigo Bagtas to retain possession of the fishpond, directly contravened the final and executory Decision of the Court of Appeals dated April 11, 1991. This decision explicitly ordered petitioners, including all persons claiming rights under them, to desist from taking possession, management, administration, and operation of the fishpond until the question of ownership was finally adjudicated. The Supreme Court emphasized that when a judgment of a superior court is remanded to the trial court for execution, the trial court's function is purely ministerial; it must enforce the judgment without modification or reversal. The Court will not countenance attempts to evade or frustrate a final and executory resolution. On the issue of permissible intervention: The Court reiterated the firmly settled rule that intervention is no longer permissible after trial and when judgment has become final and executory. Rule 12, Section 2 of the Revised Rules of Court provides that intervention may be permitted before or during a trial. In this case, Mr. Bagtas intervened only at the execution stage, after the case had been decided by the trial court, the Court of Appeals, and the Supreme Court, and the decision had attained finality. The trial court committed a clear and grave abuse of discretion amounting to lack of jurisdiction in allowing intervention at this late stage and in rendering orders inconsistent with the final decision.
Main Doctrine
The trial court committed grave abuse of discretion amounting to lack of jurisdiction in issuing orders that contravened a final and executory decision of the Court of Appeals, particularly by allowing intervention and modifying possession during the execution stage.