GR L 4855; (July, 1908) (Digest)

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📌 CORE DOCTRINE

“A court retains jurisdiction to enforce its final judgment through execution, even if a third-party creditor has attached the judgment debtor's claim in a separate proceeding, as such attachment does not divest the original court of its authority over the case.”

💡 PLAIN ENGLISH SUMMARY

When a court makes a final decision, it has the power to make sure that decision is carried out, even if someone else is also trying to collect money from the same debt. In this case, the court could still order the debtor to pay, despite another creditor's claim, because the original court's authority wasn't taken away by that separate legal action.

📜 LEGAL MAXIM

Res judicata pro veritate accipitur | Judicium semper pro veritate accipitur

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FACTS:
A judgment was rendered by the Court of First Instance (CFI) of Pangasinan in favor of TAN CHU CHAY against ISABELO ARTACHO for P3,430, with interest and costs. This judgment was affirmed by the Supreme Court and subsequently remanded to the CFI for execution. An execution writ was issued and delivered to the provincial sheriff, Antonio Sison. When Sheriff Sison demanded payment, ARTACHO refused, alleging that the debt he owed to TAN CHU CHAY had been legally attached by the sheriff of Manila in a separate suit brought by a creditor of TAN CHU CHAY. Upon being informed of ARTACHO‘s refusal, the CFI Judge, Jas. C. Jenkins, ordered the issuance of a second execution. ARTACHO then filed an original action for certiorari with the Supreme Court, obtaining a temporary injunction.

ISSUE:
Did the Court of First Instance of Pangasinan act in excess of its jurisdiction in ordering the issuance of a second execution, given that the debt owed by ARTACHO to TAN CHU CHAY had allegedly been attached by another court?

RULING:
No. The Supreme Court ruled that the CFI of Pangasinan did not exceed its jurisdiction.
The CFI of Pangasinan had jurisdiction over the original case of TAN CHU CHAY vs. ARTACHO, encompassing both the parties and the subject matter. The mere fact that a creditor of TAN CHU CHAY had attached the debt due from ARTACHO did not divest the Pangasinan court of its jurisdiction to proceed with the execution of its judgment. Thus, the action for certiorari cannot be maintained as there was no excess of jurisdiction. The Court did not decide on other potential remedies for ARTACHO to prevent double payment. The demurrer to ARTACHO‘s complaint was sustained, with leave to amend.

G.R. No. L-4855, ISABELO ARTACHO, plaintiff, vs. TAN CHU CHAY, JAS. C. JENKINS, as Judge of the Court of First Instance of Pangasinan, and ANTONIO SISON, as sheriff of said province, defendants. July 30, 1908.

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