G.R. No. 101614 August 17, 1994
SPOUSES LORENZITO BUAN AND AMELIA BUAN, petitioners-appellants, vs. COURT OF APPEALS AND SPOUSES NATIVIDAD LA TORRE AND GUILLERMO LA TORRE, respondents-appellees.

FACTS

Private respondents, the La Torre spouses, obtained a favorable money judgment against G.L. Mejia Enterprises, Inc. To enforce the judgment, two parcels of land owned by the judgment debtor were levied. The first parcel (TCT No. 21846) was auctioned and sold to the La Torre spouses. A notice of levy was inscribed on the second parcel (TCT No. 21882). Petitioners, the Buan spouses, had earlier (July 15, 1977) entered into a deed of assignment with Estanislao David, assuming David’s obligation to buy the second parcel from G.L. Mejia Enterprises, Inc. by installments. The Buan spouses completed payment and a deed of absolute sale was executed in their favor on January 15, 1982. When they sought registration, they discovered the notice of levy annotated on the title. A new title (TCT No. 60152) was issued to them, but the annotation was carried over. The Buan spouses filed actions to cancel the notice of levy and quiet title. The trial court ruled in their favor, but the Court of Appeals (CA-G.R. No. 14768) reversed, ordering the cancellation of the Buan spouses’ title and issuance of a new one to the La Torre spouses. The Buan spouses’ petitions to the Supreme Court (G.R. Nos. 85813 & 88648) were denied, making the CA decision final. The La Torre spouses moved for execution. Meanwhile, the Buan spouses filed a separate damages case with a prayer for injunction (Branch 56, RTC Angeles City). The court (Branch 56) issued a preliminary injunction (May 8, 1990) and later a permanent injunction (August 8, 1990) with damages, enjoining the cancellation of TCT No. 60152. The La Torre spouses filed a mandamus petition with the Court of Appeals to compel the Register of Deeds to cancel the title. The Court of Appeals granted mandamus, setting aside the preliminary injunction order from Branch 56, ruling it interfered with the execution of a final judgment by a coordinate court (Branch 58). The Buan spouses appealed.

ISSUE

1. Whether the Court of Appeals erred in not resolving the issue of overpayment (i.e., whether the prior execution sale of the first parcel already fully satisfied the money judgment, making the levy on the second parcel excessive).
2. Whether the Court of Appeals erred in setting aside the preliminary injunction order of May 8, 1990, and the effect of this on the entire proceedings and the permanent injunction in the damages case.

RULING

1. Yes, the Court of Appeals erred in not resolving the issue of overpayment. While the CA decision in CA-G.R. No. 14768 was final, procedural rules may be suspended to promote substantial justice. The Supreme Court found that the judgment award (P16,729.00 plus interest and attorney’s fees) had already been fully satisfied by the prior execution sale of the first parcel (TCT No. 21846) for P33,958.54. Therefore, the subsequent levy on the second parcel (TCT No. 60152) constituted overpayment. Allowing execution on the second parcel would result in unjust enrichment for the La Torre spouses and unlawful deprivation for the Buan spouses.
2. The Court of Appeals correctly set aside the preliminary injunction order, as a trial court (Branch 56) has no power to interfere by injunction with the orders or judgments of a coordinate court (Branch 58). However, the Court of Appeals’ decision also necessarily included the nullification of the subsequent permanent injunction issued in the same damages case, as it was a necessary consequence. Nevertheless, the issue of execution was rendered moot by the resolution of the first issue. The levy on TCT No. 60152 was invalid due to overpayment.
The Supreme Court SET ASIDE the appealed decision of the Court of Appeals and REINSTATED the trial court’s order cancelling the annotation of the notice of levy on TCT No. 60152. Costs against private respondents.