Barroso v. Omelio
REITERATIONFacts
The Antecedents: Petitioner Edgar T. Barroso filed a complaint for sum of money against Dennis Li with the Regional Trial Court of Davao City, Branch 16 (RTC-Br. 16). RTC-Br. 16 granted petitioner's application for a Writ of Attachment and approved the corresponding attachment bond. Dennis Li filed a counter-attachment bond purportedly issued by respondent Travellers Insurance & Surety Corporation (Travellers). Procedural History: A Judgment on Compromise Agreement was issued by RTC-Br. 16 after Dennis Li failed to pay the sums agreed upon. A Writ of Execution was issued solely against Dennis Li, which was returned unsatisfied. Petitioner then filed a Motion for Execution of Judgment upon the Counterbond. RTC-Br. 16, after a summary hearing and finding Travellers liable, issued an Order dated April 2, 2009, justifying the issuance of an Alias Writ of Execution against both Dennis Li and Travellers based on its counterbond. An Alias Writ of Execution was issued on April 28, 2009. Travellers, instead of appearing before RTC-Br. 16, filed a separate case with the Regional Trial Court of Davao City, Branch 14 (RTC-Br. 14) for Declaration of Nullity, Prohibition, Injunction with Prayer for Writ of Preliminary Injunction & Temporary Restraining Order (TRO), and Damages. RTC-Br. 14 issued an Order dated July 29, 2009, granting the writ of preliminary injunction, enjoining Sheriff Anggot from implementing the Writ of Execution dated April 28, 2009. Petitioner's motion for reconsideration was denied by RTC-Br. 14 in an Order dated September 15, 2010. The Petition: Petitioner filed a Petition for Certiorari under Rule 65 of the Rules of Court, praying for the reversal of the Orders dated July 29, 2009, and September 15, 2010, alleging that respondent judge committed grave abuse of discretion amounting to lack or in excess of jurisdiction and gross ignorance of the law.
Issue(s)
Whether respondent judge committed grave abuse of discretion amounting to lack or excess of jurisdiction by issuing a writ of preliminary injunction to enjoin the execution of a judgment of a co-equal court. Whether respondent judge committed grave abuse of discretion by issuing the writ of preliminary injunction without requiring Travellers to put up an injunction bond. Whether respondent judge committed gross ignorance of the law by assuming jurisdiction over an action for prohibition and injunction against the executive sheriff of a co-equal court.
Ruling
The Supreme Court GRANTED the petition, SET ASIDE, and declared NULL and VOID the Orders dated July 29, 2009, and September 15, 2010, issued by the Regional Trial Court of Davao City, Branch 14.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing an injunction against a co-equal court: The Supreme Court held that the respondent judge committed grave abuse of discretion amounting to lack or excess of jurisdiction. The Court reiterated the time-honored principle that no court has the power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction. The RTC-Br. 14 judge does not have jurisdiction to hinder the enforcement of an order of a co-equal court, which had exclusive jurisdiction to correct its own issuances. Therefore, the writ of preliminary injunction issued was a patent nullity. On the issue of issuing an injunction without an injunction bond: While the petition raised this point, the Court's primary focus and ruling centered on the lack of jurisdiction of RTC-Br. 14 to issue the injunction in the first place. The impropriety of issuing an injunction against a co-equal court rendered the question of the bond moot, as the injunction itself was void. The Court emphasized that the proper recourse was to assail the implementation of the writ before the issuing court or seek redress through a higher judicial body. On the issue of assuming jurisdiction over an action for prohibition and injunction against the executive sheriff of a co-equal court: The Supreme Court found that the respondent judge's action constituted gross ignorance of the law. The doctrine of judicial stability or non-interference in the regular orders or judgments of a co-equal court is an elementary principle. A court that acquires jurisdiction over a case and renders judgment has jurisdiction over its judgment for its execution and all its incidents, to the exclusion of all other coordinate courts. The proper remedy against a perceived error in an execution order is not to resort to another co-equal body but to a higher court with the authority to nullify the action of the issuing court, such as through a petition for certiorari.
Main Doctrine
A Regional Trial Court judge commits grave abuse of discretion amounting to lack or excess of jurisdiction when they issue a writ of preliminary injunction to hinder the enforcement of an order or judgment of a co-equal court, as the latter court has exclusive jurisdiction to correct its own issuances.