G.R. No. L-27274. January 30, 1982.
ROSITA YAP VDA. DE CHI, petitioner, vs. HON. SANTIAGO O. TAÑADA, Presiding Judge of Br. V of the Court of First Instance of Cebu, SOUTHERN ISLANDS HOSPITAL and CHONG HUA HOSPITAL, respondents.

FACTS

Petitioner Rosita Yap Vda. de Chi was injured in a vehicular accident involving a bus owned by Alfonso Corominas, Jr. and driven by Simplicio Lawas. She filed an action for damages against them. The vehicle was insured with Capital Insurance & Surety Co., Inc., which was impleaded as a third-party defendant. The trial court rendered a final and executory judgment ordering the defendants and the driver to pay the petitioner P40,302.31 jointly and severally, and the surety company to indemnify Corominas, Jr. for this amount.
During execution, with only a portion of the judgment amount remaining unpaid, the respondent hospitals (Southern Islands Hospital and Chong Hua Hospital), which were not parties to the original case, filed motions directly with the trial court. They sought and obtained orders directing the defendants and the surety to pay the hospitals specific sums (P686.35 and P4,238.56, respectively) from the balance owed to the petitioner, claiming these amounts represented her unpaid hospital bills. The petitioner moved for reconsideration, arguing the hospitals had no legal personality to intervene post-judgment and that the orders effectively altered the final judgment.

ISSUE

Whether the respondent trial court acted without or in excess of jurisdiction or with grave abuse of discretion in issuing the orders directing payment from the judgment award directly to the non-party hospitals after the judgment had become final and executory.

RULING

Yes. The Supreme Court annulled the trial court’s orders. The legal logic is anchored on the doctrine of finality of judgment and the rules governing execution and intervention. A final and executory judgment can no longer be altered or amended, and the court’s ministerial duty is limited to its execution according to its terms. The judgment in this case specifically ordered payment of a lump sum to the petitioner, not to any other entity.
The respondent hospitals, not being parties to the case, had no legal personality to intervene at the execution stage. Intervention under the Rules of Court is allowed only before or during the trial, not after a final judgment has been rendered. The trial court’s orders effectively modified the final judgment by diverting part of the award to non-parties, which is a substantive alteration beyond the court’s power during execution. The hospitals’ proper remedy is to file separate collection suits against the petitioner, where she can raise any personal defenses. The trial court’s acts, therefore, constituted grave abuse of discretion for being issued without jurisdiction and in violation of the petitioner’s right to due process.