G.R. No. 213054 , June 15, 2016
TERESITA TAN, PETITIONER, VS. JOVENCIO F. CINCO, SIMON LORI HOLDINGS, INC., PENTACAPITAL INVESTMENT CORPORATION, FORTUNATO G. PE, RAYMUNDO G. PE, JOSE REVILLA REYES, JR., AND DEPUTY SHERIFF ROMMEL IGNACIO, RESPONDENTS.

FACTS

In 2001, respondents extended a loan to Dante Tan, secured by his shares. Upon Dante’s default, respondents filed a collection case (Civil Case No. 01-357) before the Makati RTC, which ruled in their favor. A writ of execution was issued. To enforce it, Deputy Sheriff Rommel Ignacio levied on a property registered in Dante’s name (subject property) and conducted an auction sale on March 29, 2005. Dante sought to quash the writ, presenting an affidavit from his wife, petitioner Teresita Tan, attesting to the conjugal nature of the property. The Makati RTC denied Dante’s motions, ruled the levy was valid, and directed the issuance of a writ of possession. This became final and executory.
On May 2, 2007, Teresita filed a separate complaint before the Parañaque RTC (Civil Case No. 07-0134) against respondents and the sheriff, seeking nullification of the auction sale and related certificates. The Parañaque RTC initially dismissed the case on grounds of res judicata but later, upon reconsideration, reversed itself and nullified the auction sale, certificate of sale, and Final Deed of Sale. It held Teresita was a third party to the Makati case and her affidavit submission did not make her a party thereto.
Respondents received the Parañaque RTC’s denial of their motion for reconsideration on May 23, 2011. They initially sought to file a certiorari petition with the CA but, realizing their error, withdrew that motion and instead filed a Notice of Appeal with the Parañaque RTC on June 17, 2011, which was ten days late. The Parañaque RTC denied the Notice of Appeal for being filed out of time. Respondents then filed a certiorari petition with the CA, which granted it and directed the allowance of the appeal, citing the doctrine of judicial stability and finding sound reasons for exceptional allowance. Teresita’s motion for reconsideration was denied.

ISSUE

Whether the Parañaque RTC violated the doctrine of judicial stability when it took cognizance of the nullification case and declared the auction sale and related documents null and void.

RULING

Yes. The Supreme Court ruled that the Parañaque RTC violated the doctrine of judicial stability. The doctrine prohibits a court from interfering with the judgments or orders of a co-equal court of concurrent jurisdiction. A court that acquires jurisdiction over a case and renders judgment has jurisdiction over its execution and all incidental proceedings, to the exclusion of other coordinate courts. The Makati RTC, having rendered a final judgment in the collection case and issued the writ of execution, retained jurisdiction over all incidents arising from its execution, including the levy and sale of the subject property. The Parañaque RTC, a court of equal rank, had no authority to nullify the execution proceedings conducted by the Makati RTC. The proper remedy for any alleged invalidity in the execution proceedings was to seek relief from the Makati RTC itself or through a petition for certiorari with a higher court, not by filing a separate action in a co-equal court. Consequently, the Parañaque RTC acted without jurisdiction. The Supreme Court granted the petition, reversed the CA Decision and Resolution, and reinstated the Parañaque RTC’s initial order dismissing Civil Case No. 07-0134. All subsequent proceedings and orders in that case were declared null and void for lack of jurisdiction.