G.R. No. L-69623 May 31, 1985
MASAGANA TELAMART, INC., AND DAVID S. TIU, petitioners, vs. INTERMEDIATE APPELLATE COURT AND RODOLFO G. MERTO, respondents.

FACTS

Petitioners Masagana Telamart, Inc. and David S. Tiu filed an ejectment case against private respondent Rodolfo G. Merto in the City Court of Manila, which ruled in their favor on February 9, 1982. Instead of a regular appeal, Merto filed a petition for certiorari with the Court of First Instance (CFI) of Manila, challenging the decision. The CFI initially dismissed this petition but later reinstated it. Petitioners then elevated the matter to the Intermediate Appellate Court (IAC), which set aside the CFI’s reinstatement order. Merto’s subsequent petition to the Supreme Court (G.R. No. 66798) was denied with finality on May 7, 1984, and an entry of judgment was issued.
While the certiorari proceedings were ongoing, Merto filed a separate action for annulment of the ejectment judgment in the Regional Trial Court (RTC) of Manila on May 18, 1983. The RTC dismissed this annulment case on the ground of res judicata. Merto appealed this dismissal to the IAC, which then issued a resolution on December 28, 1984, granting a writ of preliminary injunction to restrain the execution of the final and executory ejectment judgment. Petitioners assail this IAC resolution before the Supreme Court.

ISSUE

Whether the Intermediate Appellate Court committed a grave abuse of discretion in issuing a resolution that restrained the execution of a final and executory judgment in an ejectment case through a separate annulment suit that raised substantially identical issues.

RULING

The Supreme Court granted the petition and set aside the IAC’s resolution. The Court ruled that the IAC’s issuance of an injunction against the execution of a final judgment constituted a grave abuse of discretion. The legal logic is anchored on the principles of finality of judgment, res judicata, and the prohibition against multiplicity of suits. The ejectment judgment had already attained finality after Merto’s certiorari petition was ultimately dismissed by the Supreme Court. The subsequent annulment case filed by Merto in the RTC involved substantially the same parties, causes of action, and reliefs sought as his earlier certiorari petition. Therefore, the final judgment in the first proceeding (the certiorari case) barred the second proceeding (the annulment case) under the doctrine of res judicata.
The Court condemned Merto’s use of sequential, overlapping suits as a clear dilatory tactic designed to unjustly deprive the winning party of the fruits of a final verdict. It emphasized that litigation must end at some definite point to ensure effective and efficient administration of justice. Allowing a losing party to indefinitely forestall execution through repetitive suits raising the same issues makes a mockery of the judicial system. Consequently, the annulment case before the IAC was ordered dismissed for being moot and academic.