The Supreme Court, in this consolidated case, reiterated the principle of judicial stability. It ruled that a Regional Trial Court (RTC) cannot interfere with the judgment of a co-equal RTC. This means that once a court of competent jurisdiction renders a final decision, other courts with concurrent jurisdiction cannot modify or vacate that judgment. This ensures an orderly and efficient administration of justice by preventing conflicting rulings from different courts regarding the same matter, thus preserving the integrity and finality of judicial decisions.

Challenging Finality: When Can Courts Revisit Concluded Cases?

These consolidated cases arose from a dispute between Jose Cabaral Tiu (petitioner) and First Plywood Corporation (FPC) concerning a settlement agreement. As a settlement of FPC’s debt to Tiu, FPC allowed Tiu to cut and haul logs from its timber concession areas. When FPC allegedly prevented Tiu from accessing these areas, Tiu filed a case with the Regional Trial Court (RTC) of Pagadian City. The Pagadian RTC rendered a judgment based on a Compromise Agreement forged between Tiu and FPC. Subsequently, an execution sale of FPC’s properties took place to satisfy the judgment. However, FPC later filed separate cases in the Manila RTC and the Antipolo RTC, seeking to annul the execution sale. This prompted the Supreme Court to address the critical issue of whether one RTC can annul the decision and execution sale ordered by another RTC of equal jurisdiction.

The Manila RTC ruled in favor of FPC, nullifying the execution sale. The court reasoned that the sale was conducted without proper notice. On appeal, the Court of Appeals dismissed Tiu’s petition for annulment of judgment, leading to G.R. No. 176123 before the Supreme Court. Meanwhile, TEI and Angel Domingo filed a similar case in the Antipolo RTC, also seeking to annul the execution sale. The Antipolo RTC initially dismissed the complaint, but the Court of Appeals reversed this decision, leading to G.R. No. 185265. The Supreme Court consolidated these cases to resolve the common issue of the validity of the Pagadian case execution sale and the propriety of the subsequent actions filed in the Manila and Antipolo RTCs.

The Supreme Court emphasized that the validity of the Pagadian case execution sale was central to resolving both petitions. It reiterated the presumption of regularity in the performance of official functions, which means that the sheriff is presumed to have properly performed his duty of providing notice of the sale unless there is clear and convincing evidence to the contrary. The Court noted that FPC failed to provide sufficient evidence to rebut this presumption, and the Manila RTC erred by placing the burden of proof on the sheriff. According to the Supreme Court, “[a]part from its bare allegations, it has not come forward with any evidence, let alone a clear and convincing one, of non-compliance with the requirement of a minimum of five days prior notice of sale of property on execution.”

The Court then addressed the issue of jurisdiction. It found that the Manila RTC lacked jurisdiction over the nature of the action filed by FPC. The Court explained that the Pagadian RTC, which rendered the original decision and ordered the execution sale, was the proper venue to settle the controversy. The Supreme Court underscored the principle of judicial stability, stating: “[p]ursuant to the principle of judicial stability, the judgment or order of a court of competent jurisdiction, Pagadian RTC in this case, may not be interfered with by any court of concurrent jurisdiction (i.e., another RTC), for the simple reason that the power to open, modify or vacate the said judgment or order is not only possessed by but is restricted to the court in which the judgment or order is rendered or issued.”

This principle is crucial for maintaining order and preventing chaos in the judicial system. Permitting courts of equal jurisdiction to interfere with each other’s judgments would lead to endless litigation and undermine the finality of judicial decisions. As the Court noted, a judgment rendered without jurisdiction is null and void and may be attacked at any time. The Court has consistently held that the choice of the proper forum is crucial, and a decision from a court without jurisdiction is a total nullity.

The Supreme Court also addressed FPC’s attempt to use Timber Exports, Inc. (TEI), a sister company, to challenge the execution sale in the Antipolo RTC. The Court saw through this attempt, recognizing it as a ruse to circumvent the final and executory judgment of the Pagadian RTC. The Court declared, “[t]his Court would be the last to sanction such a brazen abuse of remedies and disrespect of judicial stability. What is clear is that FPC is feebly attempting to disturb the effects of a judgment that, by its failure to appeal, had long become final and been the subject of execution. This cannot be allowed without running afoul of the settled doctrine of finality of judgment.”

The principle of finality of judgment is a cornerstone of the judicial system. Once a judgment becomes final and executory, it is immutable and unalterable, regardless of whether the modification is intended to correct an erroneous conclusion of fact or law. This principle ensures that litigation must eventually end, and once a judgment has become final, the issue or cause involved therein should be laid to rest. The Court emphasized that utmost respect and adherence to this principle must always be maintained by those who wield the power of adjudication, and any act that violates it must be struck down.

The Supreme Court explicitly cited the rule pertaining to notice of sale of property on execution: “Sec. 18. Notice of sale of property on execution. – Before the sale of property on execution, notice thereof must be given as follows: (b) In case of other personal property, by posting a similar notice in three public places in the municipality or city where the sale is to take place, for not less than five (5) nor more than ten (10) days…”

The Supreme Court granted both petitions, setting aside the Court of Appeals’ resolutions and decisions in both cases. In G.R. No. 176123, the Court declared the Manila RTC Decision of July 16, 2001, null and void. In G.R. No. 185265, the Court reinstated the Antipolo RTC’s decision dismissing the complaint, but on the ground of lack of jurisdiction, rather than the reasons originally cited by the Antipolo RTC. The Supreme Court decision reaffirms the importance of respecting the jurisdiction of courts and upholding the principle of finality of judgments.

FAQs

What was the central issue in this case?	The key issue was whether one Regional Trial Court (RTC) could annul the decision and execution sale ordered by another RTC of equal jurisdiction. This question hinged on the principle of judicial stability and the finality of judgments.
What is the principle of judicial stability?	The principle of judicial stability holds that a court of competent jurisdiction’s judgment or order cannot be interfered with by any court of concurrent jurisdiction. This means that once a court has decided a matter, other courts of equal standing cannot modify or vacate that decision.
Why is the principle of finality of judgment important?	The principle of finality of judgment ensures that litigation must eventually come to an end. Once a judgment becomes final and executory, it is immutable and unalterable, even if there are perceived errors of fact or law.
What happens if a court renders a judgment without jurisdiction?	A judgment rendered by a court without jurisdiction is null and void and can be attacked at any time. Such a judgment creates no rights and produces no legal effect.
What was the basis for the Manila RTC’s decision to annul the execution sale?	The Manila RTC annulled the execution sale, arguing that the sale was conducted without proper notice, as required by the Rules of Court. However, the Supreme Court found that FPC failed to provide sufficient evidence to support this claim.
What was the Supreme Court’s ruling on the Manila RTC’s decision?	The Supreme Court declared the Manila RTC’s decision null and void for lack of jurisdiction. It held that the Pagadian RTC, which rendered the original decision and ordered the execution sale, was the proper venue to settle any disputes arising from that decision.
What was the role of Timber Exports, Inc. (TEI) in this case?	TEI, a sister company of FPC, filed a separate case in the Antipolo RTC seeking to annul the same execution sale. The Supreme Court viewed this as a ruse by FPC to circumvent the final judgment of the Pagadian RTC.
What was the Supreme Court’s ultimate decision in these consolidated cases?	The Supreme Court granted both petitions, setting aside the Court of Appeals’ resolutions and decisions in both cases. It declared the Manila RTC’s decision null and void and reinstated the Antipolo RTC’s decision dismissing the complaint, but on the ground of lack of jurisdiction.

This case serves as a critical reminder of the importance of respecting judicial processes and the principle of finality in judgments. The Supreme Court’s decision reinforces the idea that courts must act within their jurisdiction and that attempts to circumvent final judgments will not be tolerated. The case underscores the need for parties to diligently pursue their legal remedies within the proper forums and timeframes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: JOSE CABARAL TIU vs. FIRST PLYWOOD CORPORATION, G.R. No. 176123, March 10, 2010