GR 208543; (February, 2019) (Digest)
G.R. No. 208543 February 11, 2019
GOODLAND COMPANY, INC., Petitioner vs. BANCO DE ORO-UNIBANK, INC., AND GOODGOLD REALTY AND DEVELOPMENT CORPORATION, Respondents
FACTS
Petitioner Goodland Company, Inc., along with other corporations including respondent Goodgold Realty, obtained loans from Equitable PCI Bank (EPCI), which later merged with respondent Banco De Oro Unibank, Inc. (BDO). The debtors failed to pay, leading to a Dacion En Pago agreement where Goodgold’s property would settle the obligation. However, BDO alleged fraud, claiming the debtors refused to submit transfer documents to consummate the dacion. BDO filed a Complaint for a Sum of Money with Application for Preliminary Attachment. The Regional Trial Court (RTC) issued a writ of preliminary attachment covering properties of Goodland and Goodgold.
The RTC later issued orders partially discharging some attached properties. Both BDO and Goodland filed separate Petitions for Certiorari before the Court of Appeals (CA), docketed as CA-G.R. SP No. 117223 (BDO’s petition) and CA-G.R. SP No. 119327 (Goodland’s petition). The CA’s Sixth Division, in CA-G.R. SP No. 117223, granted BDO’s petition and reinstated attachments on certain properties. Subsequently, the CA’s Former Sixth Division, in CA-G.R. SP No. 119327, dismissed Goodland’s petition, effectively affirming the RTC order attaching Goodland’s property. Goodland filed this Petition for Review.
ISSUE
Whether the Court of Appeals, in CA-G.R. SP No. 119327, committed reversible error in dismissing Goodland’s petition and upholding the writ of preliminary attachment against its property.
RULING
The Supreme Court denied the petition. The core legal principle applied is the policy of judicial stability, which mandates that a division of the appellate court should not interfere with or modify the decision of a co-equal division. The CA’s Sixth Division, in CA-G.R. SP No. 117223, had already ruled on the propriety of the writ of preliminary attachment, including matters pertaining to Goodland’s property. The CA’s Former Sixth Division, in CA-G.R. SP No. 119327, correctly refrained from revisiting or overturning these settled issues.
The logic is that allowing one division to nullify or amend the orders of another would lead to conflicting decisions, confusion, and a serious hindrance to the administration of justice. The two CA cases involved a common question—the validity of the RTC’s orders regarding the discharge of attachment—and were intrinsically related. Judicial stability requires that once a matter has been decided by one division, it becomes binding on other divisions to promote consistency and respect for the court’s authority. Therefore, the CA in SP No. 119327 committed no error in dismissing Goodland’s petition, as doing otherwise would have violated this fundamental policy. The Supreme Court found no compelling reason to deviate from this established doctrine.