GR 157671; (June, 2006) (Digest)
G.R. No. 157671 ; June 20, 2006
DANILO G. PUNONGBAYAN, Petitioner, vs. PERFECTO G. PUNONGBAYAN, JR., MARILOU P. VISITACION, and SOTERO A. PUNONGBAYAN, Respondents.
FACTS
St. Peter’s College, a non-stock corporation, was governed by a five-member Board of Trustees. By 1995, only three trustees remained: petitioner Danilo, respondent Perfecto Jr., and respondent-intervenor Sotero. Due to deadlock and lack of quorum, Sotero filed a petition with the Securities and Exchange Commission (SEC) in 1998, praying for the creation of a management committee. The SEC granted this, issuing an Order on November 10, 1998, creating a committee and appointing its members on February 24, 1999. No appeal was taken from these SEC Orders.
The case was later transferred to the Regional Trial Court (RTC) pursuant to Republic Act No. 8799 . Sotero then filed a motion to abolish the SEC-created management committee. The RTC, instead of abolishing it, issued Orders on June 5 and 20, 2001, effectively revamping and appointing a new three-member management committee. Perfecto Jr. and the corporate secretary filed a petition for certiorari with the Court of Appeals, assailing these RTC Orders.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion in issuing the June 5 and 20, 2001 Orders that effectively altered the management committee created by the Securities and Exchange Commission.
RULING
Yes, the RTC committed grave abuse of discretion. The Court of Appeals’ decision, which the Supreme Court affirmed, held that the SEC Orders dated November 10, 1998, and February 24, 1999, which created and appointed the members of the first management committee, had long become final and executory for lack of any appeal. The doctrine of finality and immutability of judgments dictates that a final judgment can no longer be amended, modified, or set aside by any court. The RTC, upon assuming jurisdiction over the transferred case, could not validly issue orders that effectively abolished the existing committee and constituted a new one, as this constituted an alteration of a final and implemented SEC Order. The RTC’s act was capricious and in excess of its jurisdiction. The proper course was to recognize the continuing validity of the SEC-constituted committee. The Supreme Court denied the petition and affirmed the Court of Appeals’ decision setting aside the impugned RTC Orders.