Cabigao v. Lim Y Pineda
REITERATIONFacts
The Antecedents: In civil case No. 18451, Tomas Cabigao vs. Eugenio Lim y Pineda, the Court of First Instance of Manila (second branch) rendered judgment in favor of the plaintiffs for P379, with legal interest and costs. This judgment was affirmed by the Supreme Court. Procedural History: Upon remand, the judge of the second branch issued a writ of execution, and the sheriff levied upon the property of the defendant, Eugenio Lim y Pineda. The Petition: Eugenio Lim y Pineda filed a petition in the first branch of the Court of First Instance of Manila, praying for a preliminary injunction to restrain the sheriff from carrying out the execution. The grounds cited were the pendency of another action between the same parties in the Supreme Court, wherein the defendant in execution had obtained a judgment for a larger amount. The respondent judge of the first branch issued a temporary injunction.
Issue(s)
Whether a court of coordinate jurisdiction may issue an injunction to interfere with the execution of a judgment rendered by another court of coordinate jurisdiction. Whether an inferior court may interfere with the mandate of a superior court.
Ruling
The petition for a writ of prohibition is granted. The temporary injunction issued by the respondent judge is declared null and void. The respondents are commanded to desist from interfering with the execution of the judgment in civil case No. 18451. Eugenio Lim y Pineda is ordered to pay the costs.
Ratio Decidendi
On the issue of interference between coordinate courts: The Court held that no court has the power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction having equal power to grant the relief sought. The various branches of the Court of First Instance of Manila are considered coordinate courts, and allowing them to interfere with each other's judgments would lead to confusion and hinder the administration of justice. This principle is supported by a significant weight of authority from various jurisdictions. On the issue of interference with a superior court's mandate: The Court reiterated its ruling in Shioji vs. Harvey that inferior courts cannot vary the mandate of a superior court. They cannot examine it for any purpose other than execution, nor give any other or further relief. They cannot review it upon any matter decided on appeal for error apparent, nor intermeddle with it further than to settle so much as has been remanded. The respondent judge's action constituted an unlawful interference with the functions of both the second branch of the Court of First Instance and the Supreme Court.
Main Doctrine
A court cannot interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction having equal power to grant the relief sought. Inferior courts cannot vary the mandate of a superior court, nor give any other or further relief, nor review it upon any matter decided on appeal for error apparent, nor intermeddle with it further than to settle so much as has been remanded.