Tan v. Cinco
REITERATIONFacts
The Antecedents: In 2001, respondents Simon Lori Holdings, Inc. (SLHI), Fortunato G. Pe, Raymundo G. Pe, Jovencio F. Cinco, and Jose Revilla Reyes, Jr., facilitated by PentaCapital Investment Corporation, extended a P50,000,000.00 loan to Dante Tan, secured by his shares in Best World Resources Corporation (BWRC). Upon Dante's failure to repay, he proposed to settle the debt by selling his BWRC shares, but subsequently disappeared. Respondents filed a collection case against Dante, and the Regional Trial Court of Makati City (Makati RTC) ordered him to pay P100,100,000.00. A Writ of Execution was issued, leading to the levy and auction sale of a property registered in Dante's name. Despite Dante's attempts to quash the writ, alleging the property was a family home and conjugal, the Makati RTC denied his motion, and its disposition became final. Procedural History: Teresita Tan, Dante's wife, filed a complaint before the Regional Trial Court of Parañaque City (Parañaque RTC) seeking the nullification of the auction sale and the certificate of sale. Initially, the Parañaque RTC dismissed the case on grounds of res judicata. However, upon Teresita's motion for reconsideration, the court reversed its decision, nullified the sale, and declared Teresita a third party not bound by the prior proceedings. Respondents' motion for reconsideration was denied. They then filed a Motion for Extension of Time to file a petition for certiorari with the Court of Appeals (CA), but later withdrew it and filed a Notice of Appeal with the Parañaque RTC, which was ten days late. The Parañaque RTC denied the appeal. Respondents filed a petition for certiorari with the CA, arguing the Parañaque RTC lacked jurisdiction to review the orders of a co-equal court. The Petition: The Court of Appeals granted the respondents' petition, directing the Parañaque RTC to allow the late notice of appeal, finding meritorious reasons for the exceptional allowance and citing the doctrine of judicial stability. The CA held that affirming the Parañaque RTC's orders would allow Dante to evade his adjudicated obligations based on technicality. Teresita Tan filed the present petition for review on certiorari before the Supreme Court, assailing the CA's Decision and Resolution, primarily arguing that the Parañaque RTC violated the doctrine of judicial stability by taking cognizance of the nullification case and nullifying the auction sale and related documents issued by the Makati RTC, a co-equal court.
Issue(s)
Whether the Parañaque RTC violated the doctrine of judicial stability when it took cognizance of Teresita's nullification case and declared the auction sale, certificate of sale, and Final Deed of Sale void. Whether the Parañaque RTC had jurisdiction to nullify the levy and sale of the subject property ordered by the Makati RTC.
Ruling
The petition is devoid of merit. The Order dated January 6, 2011 rendered by the Regional Trial Court of Parañaque City, Branch 257 in Civil Case No. 07-0134, the proceedings therein, as well as all orders issued thereafter are declared NULL and VOID for lack of jurisdiction.
Ratio Decidendi
On the violation of the doctrine of judicial stability: The Court held that the Parañaque RTC violated the doctrine of judicial stability when it took cognizance of Teresita's nullification case. The collection case, from which the execution proceedings emanated, fell within the jurisdiction of the Makati RTC. Therefore, the nullification case should have been dismissed at the outset for lack of jurisdiction. On the lack of jurisdiction of Parañaque RTC: The Parañaque RTC is bereft of authority to nullify the levy and sale of the subject property that was legitimately ordered by the Makati RTC, a coordinate and co-equal court. The Court reiterated the principle that a court which issued a writ of execution has the inherent power to control its own processes and to correct errors of its ministerial officers. To allow a co-equal court to interfere would lead to confusion and seriously hamper the administration of justice. The determination of whether or not the levy and sale of a property in the execution of a judgment was valid properly falls within the jurisdiction of the court that rendered the judgment and issued the writ of execution. The judgment rendered by the Makati RTC in the collection case, as well as the execution thereof, and all other incidents arising therefrom, may not be interfered with by the Parañaque RTC, a court of concurrent jurisdiction. The power to open, modify, or vacate the said judgment or order is restricted to the court in which the judgment or order is rendered or issued. Consequently, the Parañaque RTC lacked jurisdiction over the nullification case, rendering all proceedings and orders therein void for lack of jurisdiction. A judgment rendered by a court without jurisdiction is null and void and may be attacked anytime, creating no rights and producing no effect.
Main Doctrine
A court that acquires jurisdiction over a case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all its incidents. A co-equal court cannot interfere with the judgments or orders of another court of concurrent jurisdiction.