A.M. No. MTJ-89-286; March 5, 1991
Abelardo Cruz, complainant, vs. Judge Jaime N. Nicolas, respondent.

FACTS

Complainant Abelardo Cruz was the prevailing plaintiff in an ejectment case. The Municipal Trial Court (MTC) of Tarlac, Branch 1, presided by respondent Judge Jaime N. Nicolas, initially decided in his favor. This decision was reinstated with finality by the Court of Appeals on December 29, 1985. Following the finality of the judgment, complainant sought its execution. An initial writ was issued but returned unsatisfied. Complainant then moved for an alias writ.
Despite the final and executory judgment, the defendants filed a “Motion to Quash the Alias Writ of Execution” on August 11, 1987, raising new substantive claims under P.D. No. 1517 (Urban Land Reform Law). Instead of denying this improper post-judgment motion outright, respondent judge entertained it. He set it for hearing, granted multiple postponements for the defendants, allowed the filing of a supplemental motion, and ultimately required both parties to submit memoranda on the motion. This caused significant delay, compelling complainant to seek relief from the Court of Appeals, which in August 1988 ordered respondent judge to execute the decision “posthaste.”

ISSUE

Whether respondent Judge Jaime N. Nicolas is administratively liable for his actions in handling the execution of a final and executory judgment.

RULING

Yes, respondent judge is administratively liable for gross ignorance of the law and oppressive conduct. The legal logic is clear and fundamental. A final and executory judgment, such as the reinstated MTC decision in this case, is immutable and unalterable. The trial court loses all jurisdiction over the case except to issue and enforce the writ of execution. Entertaining a motion to quash a writ of execution that raises new substantive defenses, which should have been asserted during the trial or appeal, is a blatant disregard of this basic rule. By scheduling hearings, granting extensions, and requiring memoranda on the improper motion, respondent judge effectively attempted to re-litigate a settled case, depriving the prevailing party of the fruits of his victory.
This conduct constitutes gross ignorance of the law, as the principle of finality of judgments is elementary. It also amounts to oppressive delay and misconduct, undermining public confidence in the judicial process. The Court rejected the investigating judge’s recommendation of a mere reprimand as grossly inadequate. Accordingly, the Court imposed a fine of Ten Thousand Pesos (P10,000.00), a severe reprimand, and a warning that a repetition would warrant a more severe penalty.