G.R. No. 156358 ; August 17, 2011
Angelina Pahila-Garrrido, Petitioner, vs. Eliza M. Tortogo, Leonila Flores, Ananias Sedonio, Adelino Monet, Angie Monet, Juanito Garcia, Eleonor Garcia, Benita Moya, Julio Altares, Lea Altares, Clarita Sabido, Julie Ann Villamor, Juanita Tuala, Victor Flores III, Johnny Moya, Hazel Avanceña, Sonia Evangelio, and Genny Montaño, Respondents.

FACTS

On June 23, 1997, Domingo Pahila (later substituted by petitioner Angelina Pahila-Garrido) filed an ejectment suit in the Municipal Trial Court in Cities (MTCC), Bacolod City, against several defendants, including the respondents. The defendants were divided into two groups: one claiming to be agricultural tenants, and the other (the respondents) claiming the land was foreshore land belonging to the State. The MTCC ruled in favor of the petitioner on March 17, 1999, ordering the defendants to vacate. The RTC affirmed this decision on September 22, 1999. Only the respondents (the second group) appealed to the Court of Appeals, which dismissed their appeal on December 6, 1999. Their subsequent petition for certiorari to the Supreme Court (G.R. No. 143458) was rejected on July 19, 2000, and an entry of judgment was issued on October 20, 2000, making the MTCC decision final and executory. The MTCC issued a writ of execution on April 5, 2000, which was served on August 24, 2000. On April 20, 2001, the respondents filed a motion to quash the writ and to stay execution, citing a supervening event: memoranda from the DENR dated August 30, 2000 and November 13, 2000 recommending the cancellation of the petitioner’s title (TCT No. T-55630) on the ground the land was foreshore. The MTCC denied these motions on May 4, 2001 and June 8, 2001. On October 1, 2001, the respondents filed a petition for certiorari and prohibition with the RTC (SCA Case No. 01-11522), seeking to annul the MTCC orders and to enjoin the execution. The RTC granted a temporary restraining order on October 11, 2001, and later, on November 12, 2002, granted the respondents’ application for a writ of preliminary prohibitory injunction, enjoining the execution of the final MTCC decision. The petitioner directly appealed this RTC order to the Supreme Court.

ISSUE

Whether the Regional Trial Court committed a grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the order dated November 12, 2002, which granted the respondents’ application for a writ of preliminary prohibitory injunction to enjoin the execution of a final and executory judgment in an ejectment case.

RULING

Yes. The Supreme Court ruled that the RTC committed grave abuse of discretion. The Court emphasized the doctrine of finality and immutability of judgment. Once a judgment becomes final and executory, it cannot be altered, and its execution becomes a matter of right. The execution of the MTCC’s final decision in the ejectment case should not have been enjoined. The respondents’ claim of a supervening event—the DENR memoranda recommending cancellation of the petitioner’s title—was insufficient to stay execution. The memoranda were merely recommendatory and did not constitute a final, executory, and conclusive judicial or administrative ruling that altered the parties’ rights. The title remained valid until actually cancelled by a competent court. Furthermore, the RTC, in a special civil action for certiorari, could not validly issue an injunction whose effect was to control or interfere with the execution of a final judgment of an inferior court. The purpose of a preliminary injunction is to preserve the status quo, but the status quo at the time of filing the petition was that a final judgment of ejectment existed in favor of the petitioner. Enjoining its execution would alter, not preserve, that status quo. The RTC’s order was therefore issued in violation of law and settled jurisprudence. The Supreme Court granted the petition, annulled the RTC’s November 12, 2002 order, and directed the RTC to dismiss SCA Case No. 01-11522.