Dacanay v. Yrastorza
REITERATIONFacts
The Antecedents: Petitioner Vicente Dacanay, as administrator of the testate estate of Tereso D. Fernandez, filed a case for recovery of real property against respondent spouses Luissa and Raul Samaco and Roberta and Bryan Kersaw. Respondent Johnson Mercader was later impleaded. Respondent spouses Kersaw were declared in default. Procedural History: The Regional Trial Court (RTC) dismissed petitioner’s complaint for lack of merit and ordered him to pay ₱70,000 to respondent spouses Samaco and respondent Mercader for attorney’s fees, litigation expenses, and moral damages. The Court of Appeals (CA) affirmed the RTC decision in toto. Petitioner’s motion for extension to file a petition for review on certiorari with the Supreme Court was denied due to procedural lapses, and his motion for reconsideration was also denied. Consequently, the CA and Supreme Court entered judgment on their rulings, making the RTC decision final and executory. The Petition: Respondent Mercader filed a motion for execution of the RTC decision. Petitioner opposed, arguing that he should not be personally liable and that the writ should be referred to the court settling the estate of Tereso Fernandez. The RTC granted the motion for execution, stating there was no impediment as the decision was final and executory and did not involve money claims against the estate. Petitioner’s motion for reconsideration was denied. Petitioner then filed a petition for certiorari with the Supreme Court, reiterating his position against personal liability.
Issue(s)
Whether the petition for certiorari filed directly with the Supreme Court violates the doctrine of hierarchy of courts. Whether the RTC decision, having attained finality, can still be questioned or modified. Whether the RTC erred in granting the motion for execution of its final and executory decision.
Ruling
The petition is DISMISSED. Costs against petitioner. The RTC decision dismissing petitioner’s complaint and holding him personally liable for ₱70,000 to respondent spouses Samaco and respondent Mercader became final and executory and is thus subject to execution.
Ratio Decidendi
On the violation of the doctrine of hierarchy of courts: The petition for certiorari was filed directly with the Supreme Court, which is a violation of the doctrine of hierarchy of courts. The petitioner should have filed his petition in the Court of Appeals before seeking relief from the Supreme Court. This procedural infirmity is sufficient ground for the outright dismissal of the petition. On the finality and immutability of judgment: The RTC decision sought to be executed had long attained finality. Once a judgment attains finality, it becomes immutable and unalterable. It cannot be modified in any respect, even if the modification is intended to correct an erroneous conclusion of fact or law. This doctrine is grounded on fundamental considerations of public policy and sound practice, ensuring that litigations come to an end. The CA decision affirming the RTC decision became final on June 22, 2000, and the Supreme Court's resolution denying the motion for extension became final on February 14, 2001. Thus, the RTC decision was indeed final and executory. On the issuance of the writ of execution: There was no legal impediment to the RTC’s issuance of a writ of execution of its final and executory decision. The RTC correctly ruled that the decision sought to be executed was final and executory. The contention that the writ should be referred to the estate settlement court was misplaced, as the RTC decision had already become final and executory and was no longer subject to collateral attack or modification. The RTC's order granting the motion for execution was therefore proper.
Main Doctrine
A final and executory judgment is immutable and unalterable, and a writ of execution may be issued to enforce it, irrespective of any perceived error in fact or law, as the doctrine of finality of judgment is grounded on public policy and sound practice to prevent endless litigation.