G.R. No. 51283 June 7, 1989
LOURDES MARIANO, petitioner, vs. COURT OF APPEALS, and DANIEL SANCHEZ, respondents.

FACTS

The case originated from a suit filed by Esther Sanchez against Lourdes Mariano for recovery of the value of delivered dresses. The trial court ruled in favor of Mariano on her counterclaim, awarding her damages. Pending Esther Sanchez’s appeal, the trial court granted Mariano’s motion for execution pending appeal. The sheriff levied on real and personal properties belonging to the conjugal partnership of Esther and her husband, Daniel Sanchez. Esther’s petition to annul this execution was dismissed by the Court of Appeals.
Subsequently, Daniel Sanchez, in his capacity as administrator of the conjugal partnership, filed a separate complaint in the Quezon City RTC to annul the execution. He argued that conjugal assets could not answer for obligations exclusively contracted by his wife and that some levied properties were exempt. The Quezon City court issued an order setting a hearing for a preliminary injunction and commanding the sheriff to desist from the auction sale. Mariano’s petition for certiorari in the Court of Appeals was eventually dismissed, prompting her appeal to the Supreme Court.

ISSUE

The issues are: (1) whether the conjugal partnership is liable for Esther Sanchez’s judgment obligation arising from her business; and (2) whether the Quezon City RTC interfered with the execution process of the Caloocan RTC.

RULING

The Supreme Court reversed the Court of Appeals. On the first issue, the conjugal partnership is liable. It was established that Esther Sanchez engaged in business with her husband’s consent and that the profits were used for family support, such as children’s schooling and household expenses. Under Article 161(1) and (5) of the Civil Code, the conjugal partnership is liable for debts and obligations contracted by either spouse for the benefit of the partnership. Since the business income redounded to the family’s benefit, the obligation was chargeable against conjugal assets.
On the second issue, the Quezon City RTC unlawfully interfered with the execution process of a coordinate court. The Caloocan court had already ordered execution pending appeal, and its process was underway. The filing of a separate action by Daniel Sanchez in another court to annul the execution and the issuance of a restraining order against the sheriff constituted a blatant interference with a co-equal court’s jurisdiction over its own judgment’s execution. The Supreme Court emphasized that a court may not obstruct or nullify the execution processes of another court of concurrent jurisdiction. The proper remedy for any claim of exemption was a third-party claim in the very court issuing the execution, not a collateral action in a different court. Therefore, the Quezon City case was ordered dismissed.