Del Rosario vs.
Ocampo-Ferrer - In light with this, the respondent filed a complaint before the RTC
G.R. no. 215348 June 20, 2016
Perlas-Bernabe, J.
Summary: respondent Ocampo-Ferrer failed to pay back the loan petitioner
Del Rosario gave to her, so the latter sued the former in RTC Las Pinas
branch 275. They later agreed to a compromise agreement in which
petitioner agreed to be paid on a later date. Upon due date, however,
respondent still failed to pay which compelled the petitioner to move for the
execution of the decision and to consequently acquire a real property of the
former from the levy and auction sale of the govnt. The levying and sale of
her property was then contested by the respondent in a separate case on a
different court, RTC Las Pinas branch 198, but was later dismissed. The CA,
however, reversed the same and declared the levying of the prop as
procedurally defective and the sale null and void.
Doctrine: the doctrine of Judicial Stability or non-interference in the
regular orders or judgments of a co-equal court is founded on the
concept of Jurisdiction. A Court that acquires jurisdiction over the case
and renders judgment therein has jurisdiction over its judgment, to the
exclusion of all other courts, for its execution and over all incidents, and
to control, in furtherance of justice, the conduct of ministerial officers
acting in connection with this judgment.
Facts:
- Petitioner Del Rosario gave a loan to respondent Ocampo-Ferrer to
the amount of P800k which the latter secured with a parcel of land.
- Respondent defaulted in her payment, to which petitioner filed a case
in the RTC Las Pinas Branch 275 for the collection of a sum of
money.
o They later arrived on a compromise whereby respondent
bound herself to pay petitioner P1.2M on or before June 19,
2005. This was subsequently approved by the RTC.
- Respondent still failed to pay petitioner the agreed amount, so the
latter moved for the execution of the decision. Sheriff Ortiz issued a
demand/Notice to pay which respondent failed to act upon, thereby
compelling the Sheriff to levy a separate parcel of land. It was then
sold at auction to the petitioner as the sole bidder.
Las Pinas Branch 198 for the unlawful acts of the petitioner and the
Sheriff in enforcing the Writ of Execution.
o RTC Branch 198 denied the petition.
o However, upon appeal, the CA reversed the decision of the
RTC and held that it was procedurally defective as there was
no showing that respondent was made to choose which
among her properties should be levied upon.
Hence, this petition.
Held:
- Under the Doctrine of Judicial Stability or non-interference in
the regular orders or judgments of a co-equal court, the various
trial courts of a province or a city, having the same equal
authority, should not, cannot, and are not permitted to interfere
with their respective cases, much less with their orders or
judgments.
o Rationale: concept of jurisdiction: a Court that acquires
jurisdiction over the case and renders judgment therein has
jurisdiction over its judgment, to the exclusion of all other
coordinate courts, for its execution and over all incidents,
and to control, in furtherance of justice, the conduct of
ministerial officers acting in connection with this judgment
o A court which issued a writ of execution has the inherent
power, for the advancement of justice, to correct errors of its
ministerial officers and to control its own processes. To hold
otherwise is to divide the jurisdiction of the appropriate
forum in the resolution of incidents arising in execution
proceedings.
o The appropriate action of respondent, therefore, was to assail
the implementation of the writ before the Court who issued
it, which is RTC Branch 275, and, upon failure, to seek
redress to a higher judicial body.
o The Sheriff was merely enforcing a writ of execution issued
by RTC Branch 275. Consequently, its enforcement cannot
be assailed in a co-equal court such as RTC 198.