G.R. No. 260664 , August 18, 2025
DEVELOPMENT BANK OF THE PHILIPPINES, REPRESENTED BY ITS GENERAL SANTOS CITY BRANCH HEAD, MARIELA LUZ T. CORTEZ, PETITIONER, vs. MANUEL TE, RESPONDENT.

FACTS

On December 1, 2010, the Development Bank of the Philippines (DBP) filed a Petition for Indirect Contempt against respondent Manuel L. Te before the Regional Trial Court (RTC). This action stemmed from a related civil case (Civil Case No. 347) where Te, as attorney-in-fact for the Abedin group, secured a writ of replevin and received from the sheriff certificates of title and proofs of ownership that were previously surrendered to DBP as loan security. After Te moved to dismiss the civil case, the RTC issued an Order on March 2, 2004, denying the motion and directing Te to surrender the custody of all certificates of title and proofs of ownership to the trial court within 30 days. This order was reiterated on October 11, 2004. Te failed to comply, prompting DBP’s contempt petition.
On April 16, 2014, the RTC found Te guilty of indirect contempt, sentencing him to pay a fine and suffer imprisonment until compliance. The Court of Appeals (CA) affirmed this ruling. Te’s subsequent petition for review to the Supreme Court was denied, and the Court’s Resolution became final and executory on June 18, 2018.
Later, Te filed a Manifestation of Compliance before the RTC, stating he had recovered only 12 out of the 131 certificates of title and 34 proofs of ownership, and prayed that this be considered satisfactory compliance, arguing the original order was directed at the Abedin group, not him personally. On July 17, 2020, the RTC issued an Order lifting the contempt order against Te, finding his failure to return all titles did not constitute “willful disregard” as the titles were returned to the actual landowners, a matter beyond his control. DBP’s motion for reconsideration was denied.
DBP then filed a petition for certiorari before the CA, arguing the RTC committed grave abuse of discretion by lifting the contempt order despite Te’s incomplete compliance, effectively modifying a final judgment in violation of the doctrine of immutability. The CA dismissed the petition, holding the RTC did not modify a final judgment but merely gave effect to Te’s compliance, and that DBP failed to prove grave abuse of discretion. The CA also noted a lack of clear evidence on the exact number of documents involved and that Te could not be faulted for not possessing the remaining titles. DBP’s motion for reconsideration was denied, leading to this Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion when it affirmed the RTC’s ruling which lifted the judgment of indirect contempt against respondent.

RULING

The petition is impressed with merit. The Supreme Court found that the CA committed grave abuse of discretion. The RTC’s July 17, 2020 Order lifting the contempt judgment constituted an unauthorized modification of a final and executory judgment, violating the doctrine of immutability of judgments. The Court’s prior Resolution finding Te guilty of contempt had attained finality. The RTC’s act of re-evaluating the evidence and accepting Te’s partial compliance as sufficient effectively altered the final judgment’s terms, which required Te’s full compliance with the surrender order as a condition for purging the contempt. The CA’s affirmation of this unauthorized act was a patent disregard of settled legal principles, constituting grave abuse of discretion. The Supreme Court reversed the CA’s Decision and Resolution and reinstated the RTC’s April 16, 2014 Decision finding Te guilty of indirect contempt.