G.R. No. 132601, January 19, 1999.
LEO ECHEGARAY, petitioner, vs. SECRETARY OF JUSTICE, ET AL., respondents.

FACTS

Petitioner Leo Echegaray was convicted and sentenced to death, a judgment which became final. He filed a petition (G.R. No. 132601) assailing the constitutionality of Republic Act No. 8177 (the Lethal Injection Law) and its implementing rules. The Court, in a Decision, denied the petition regarding the constitutionality of R.A. No. 8177 but granted it regarding Sections 17 and 19 of its Implementing Rules, declaring them invalid and enjoining enforcement of the law until those sections were appropriately amended. This Decision became final and executory on November 6, 1998. The Secretary of Justice subsequently submitted Amended Rules and Regulations in compliance. As the date for execution neared, the Court issued a Resolution on January 4, 1999, temporarily restraining the execution. Public respondents (the Secretary of Justice, et al.) filed an Urgent Motion for Reconsideration and a Supplemental Motion, arguing that the Court lost jurisdiction after finality, that the TRO trenched on executive authority, created a dangerous precedent, and that supervening events (like a presidential veto threat and a House resolution against repeal) made repeal of the death penalty law nil.

ISSUE

Whether the Supreme Court retained jurisdiction to issue a temporary restraining order against the execution of a final and executory death sentence.

RULING

Yes. The Supreme Court retained jurisdiction to issue the TRO. The principle of finality of judgment does not mean the Court loses all power over the case. The Court loses jurisdiction to amend, modify, or alter a final judgment, but it retains jurisdiction to execute and enforce it. This includes the power to control the particulars of execution and to address circumstances that may render execution unjust or impossible. The TRO was issued in G.R. No. 132601, a separate case from the automatic review of the conviction, to preserve the status quo and prevent the execution from being rendered moot by potential legislative action (repeal or modification of the death penalty law) during the Congress’s next session. The Court’s action was a valid exercise of its judicial power and duty to ensure the execution of its own final judgment in G.R. No. 132601, which had enjoined enforcement of R.A. No. 8177 until defective implementing rules were corrected. The arguments regarding supervening events were speculative and did not guarantee that the law would not be repealed. The Court emphasized its duty to administer justice and protect constitutional rights, especially where life and liberty are at stake.