G.R. No. 146006 . April 22, 2005.
JOSE C. LEE AND ALMA AGGABAO, in their capacities as President and Corporate Secretary, respectively, of Philippine International Life Insurance Company, and FILIPINO LOAN ASSISTANCE GROUP, Petitioners, vs. REGIONAL TRIAL COURT OF QUEZON CITY, BRANCH 85, et al., and MA. DIVINA ENDERES, Respondents.

FACTS

This case originated from a petition for letters of administration concerning the intestate estate of Dr. Juvencio P. Ortañez, which included 2,029 shares in Philippine International Life Insurance Company (Philinterlife). During the proceedings, the legitimate heirs executed an extrajudicial settlement and subsequently sold the shares to petitioner Filipino Loan Assistance Group (FLAG). However, private respondent Ma. Divina Ortañez-Enderes, an illegitimate child and appointed special administratrix for the shares, contested this. The trial court declared the settlement and sale void as to the shares, an order ultimately affirmed by the Supreme Court in a final and executory Decision dated February 23, 2004. The trial court then issued a writ of execution directing petitioners, including Philinterlife’s corporate officers Jose C. Lee and Alma Aggabao, to reinstate the shares in the estate’s name and recognize the special administratrix’s rights.

ISSUE

Whether petitioners are guilty of indirect contempt for their willful refusal to comply with the final and executory judgment and related orders of the court.

RULING

Yes, petitioners are guilty of indirect contempt. The Supreme Court emphasized that a decision that has become final and executory is immutable and unalterable. The Court’s February 23, 2004 Decision had already resolved with finality the validity of the trial court’s orders nullifying the sale and affirming the special administratrix’s authority. Petitioners’ subsequent filings—including an omnibus motion for reconsideration, a motion to suspend execution based on alleged supervening events like the revocation of the special administratrix’s appointment, and arguments about share valuation—constituted prohibited pleadings that sought to re-litigate settled matters. The Court found these actions to be deliberate schemes to delay and obstruct the execution of a final judgment. Such willful disobedience of lawful court orders constitutes indirect contempt under Rule 71 of the Rules of Court, as it impedes, obstructs, and degrades the administration of justice. Accordingly, petitioners Jose C. Lee and Alma Aggabao were found guilty and fined ₱30,000 each, with a stern warning of imprisonment for further non-compliance.