First United Constructors Corp. v. Court of Appeals
REITERATIONFacts
The Antecedents: In the case of National Power Corporation (NPC) v. Alonzo-Legasto, the Supreme Court awarded the amount of Seventy Four Million Thirty-Five Thousand Five Hundred Three Pesos and Fifty Centavos (P74,035,503.50) plus interest to First United Constructors Corporation (FUCC). This amount represented just compensation for blasting work FUCC performed under a contract with NPC. The decision became final and executory on January 4, 2005. During the execution phase, Engr. Ernesto Bautista (Bautista) of Dynamic Blasting Specialist of the Philippines, claiming to be the subcontractor who actually performed the work, filed a motion in the Regional Trial Court (RTC) to have P37,723,823.00 of the award turned over to him. Procedural History: On July 18, 2005, the RTC Branch 99 granted Bautista's motion, ordering that his claim be deducted from the award due to FUCC. FUCC challenged this order, and the case was eventually re-raffled to RTC Branch 76. The presiding judge of Branch 76, Hon. Alexander S. Balut, refused to annul the July 18, 2005 Order, reasoning that one branch cannot interfere with the order of another branch of the same court and that the order had attained finality. FUCC then filed a petition for certiorari and prohibition with the Court of Appeals (CA), seeking a Temporary Restraining Order (TRO). The CA denied the TRO, stating FUCC failed to show facts entitling it to the relief. The Petition: FUCC filed this Petition for Certiorari under Rule 65 before the Supreme Court, alleging that the CA committed grave abuse of discretion in denying the TRO. FUCC argued that the RTC Order dated July 18, 2005, was a patent nullity because it altered a final and executory Supreme Court decision. FUCC further contended that the doctrine against intra-court interference was inapplicable because the case was merely re-raffled within the same court, and Branch 76 had the authority to correct the errors of the previous branch in the same proceeding.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in refusing to issue a Temporary Restraining Order. Whether the Regional Trial Court orders modifying the final award in favor of First United Constructors Corporation are valid. Whether the doctrine of intra-court interference applies when a case is re-raffled to another branch of the same court.
Ruling
The petition is GRANTED. The Resolution of the Court of Appeals dated March 30, 2006, the Order of the Regional Trial Court Branch 76 dated March 8, 2006, and the Order and Alias Writ of Execution of the Regional Trial Court Branch 99 dated July 18, 2005, and July 29, 2005, respectively, are ANNULLED AND SET ASIDE. The trial court is DIRECTED to forthwith issue an Alias Writ of Execution in accordance with the decision in National Power Corporation v. Alonzo-Legasto.
Ratio Decidendi
On Issue 1: The Court of Appeals (CA) committed grave abuse of discretion by failing to conduct an independent evaluation of the necessity for a Temporary Restraining Order (TRO). The Supreme Court had previously issued a status quo order, which indicated that First United Constructors Corporation's (FUCC) allegations regarding the trial court's unauthorized alteration of a final judgment were meritorious. By perfunctorily denying the TRO, the CA abetted the trial court's error in sustaining orders that amended a final and executory judgment. The preservation of the status quo is essential when a lower court attempts to modify a settled Supreme Court decision. The CA's failure to recognize that the trial court effectively allowed an intervention without a proper motion and re-opened a closed case constituted a whimsical exercise of judgment. On Issue 2: The Regional Trial Court (RTC) orders are void because they violated the principle of immutability of judgments. The decision in National Power Corporation (NPC) v. Alonzo-Legasto was final and executory, awarding a specific sum to FUCC alone. By directing that a portion of this award be paid to Ernesto Bautista, the trial court effectively modified and altered the dispositive portion of the decision. A court executing a judgment cannot legally reverse or modify what has already been settled by the Supreme Court. No matter how just the trial court's intention to protect a subcontractor, it lacked the jurisdiction to change the terms of a final award during the execution stage. On Issue 3: The doctrine against intra-court interference was misapplied by the RTC Branch 76. This doctrine prevents a branch of a court from interfering with the processes of another branch of the same court in a different case of coordinate jurisdiction. However, it does not apply when a judge acts in the same case that was re-raffled to their branch due to the inhibition of the previous judge. Since Branch 76 was now the presiding branch for the specific case, it had the authority and the duty to correct or annul the previous orders issued by Branch 99 in that same proceeding. The refusal to act based on this doctrine was a failure to exercise proper judicial oversight over a patently null order.
Main Doctrine
The principle of immutability of judgments dictates that once a judgment becomes final, it is immutable and unalterable. The court executing the judgment must refrain from creating further controversy by effectively modifying and altering the dispositive portion of the decision, thus further delaying the satisfaction of the judgment. No matter how just the intention of the trial court, it cannot legally reverse or modify what has already been settled by a final and executory decision of the Supreme Court.