Del Rosario v. Ocampo-Ferrer
REITERATIONFacts
The Antecedents: Respondent Cristina Ocampo-Ferrer obtained a loan of P850,000.00 from petitioner Eldefonso G. Del Rosario, secured by a parcel of land. Ocampo-Ferrer defaulted on the loan, leading Del Rosario to file a complaint for sum of money. The parties entered into a Compromise Agreement, approved by the Regional Trial Court (RTC) of Las Piñas City, Branch 275, wherein Ocampo-Ferrer agreed to pay P1,200,000.00 by June 19, 2005. Despite this agreement, Ocampo-Ferrer again failed to comply with her obligation. Procedural History: Following Ocampo-Ferrer's continued non-compliance, Del Rosario moved for execution of the Compromise Agreement, which the RTC-Las Piñas Br. 275 granted. Petitioner Sheriff Josefino Ortiz issued a demand to pay, which was unheeded. Consequently, Sheriff Ortiz levied Ocampo-Ferrer's parcel of land covered by TCT No. 30480 and conducted a public auction where Del Rosario emerged as the highest bidder, resulting in a Certificate of Sale. Ocampo-Ferrer then filed a complaint before RTC-Las Piñas Br. 198 seeking to annul the sheriff's sale and claiming damages, alleging unlawful acts by Del Rosario and Sheriff Ortiz. The RTC-Las Piñas Br. 198 dismissed Ocampo-Ferrer's complaint for lack of merit but ordered Del Rosario to return a duplicate title. Ocampo-Ferrer appealed to the Court of Appeals (CA). The Petition: The Court of Appeals reversed the RTC's decision, nullifying the levy, auction sale, Certificate of Sale, and Deed of Final Sale, citing procedural defects in the levy process. The CA held that the sheriff failed to give Ocampo-Ferrer the option to choose which property to levy and should have first levied on personal properties. Petitioners sought review via certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in nullifying the levy and sale. They contended that the RTC-Las Piñas Br. 198 lacked jurisdiction to annul actions stemming from a co-equal court's order, violating the doctrine of judicial stability.
Issue(s)
Whether the Court of Appeals (CA) correctly held that the levy and consequent sale of the property covered by TCT No. 30480 is null and void; specifically, whether RTC-Las Piñas Br. 198 had jurisdiction to annul actions emanating from a lawful order of a co-equal court, RTC-Las Piñas Br. 275.
Ruling
The petition is GRANTED. The Decision dated May 27, 2014, and the Resolution dated November 10, 2014, of the Court of Appeals in CA-G.R. CV No. 100487 are SET ASIDE. Civil Case No. LP-07-0037 is DISMISSED on the ground of lack of jurisdiction.
Ratio Decidendi
On the issue of jurisdiction and the CA's ruling: The Court held that the CA erred in reversing the RTC's decision and in declaring the levy and sale void. The levy and sale were conducted by Sheriff Ortiz in enforcement of a writ of execution issued by RTC-Las Piñas Br. 275. The doctrine of judicial stability or non-interference dictates that co-equal courts cannot interfere with each other's judgments or orders. Since the writ of execution emanated from RTC-Las Piñas Br. 275, its enforcement could not be assailed in a co-equal court like RTC-Las Piñas Br. 198. The RTC-Las Piñas Br. 198 should have dismissed the case for lack of jurisdiction, as it sought to annul actions originating from a co-equal court. The proper remedy to assail orders from RTC-Las Piñas Br. 275 would be to file an action before a higher court with the authority to nullify such orders, not before a coordinate body. Therefore, the CA's resolution of the case on the merits, instead of dismissing it on jurisdictional grounds, was erroneous. The Court emphasized that a court which issues a writ of execution has the inherent power to correct errors of its ministerial officers and control its own processes, and any violation of law in issuing such a writ should be addressed to a higher court, not a co-equal one. The CA's finding of procedural defects in the levy, while potentially valid in another context, was irrelevant given the jurisdictional bar.
Main Doctrine
A co-equal court cannot interfere with the execution of a judgment or order of another co-equal court. The remedy against an erroneous execution is to assail it before the issuing court or a higher judicial body, not a co-equal court.