GR 215348; (June, 2016) (Digest)
G.R. No. 215348, June 20, 2016
ELDEFONSO G. DEL ROSARIO AND JOSEFINO R. ORTIZ, PETITIONERS, VS. CRISTINA OCAMPO-FERRER, RESPONDENT.
FACTS
Sometime in February 2001, respondent Cristina Ocampo-Ferrer obtained a loan from petitioner Eldefonso G. Del Rosario, secured by a parcel of land. After Ocampo-Ferrer defaulted, Del Rosario filed a complaint for sum of money before the Regional Trial Court of Las Piñas City, Branch 275 (RTC-Las Piñas Br. 275). The parties entered into a Compromise Agreement, which the court approved as its Decision on December 10, 2004. Ocampo-Ferrer failed to comply, prompting Del Rosario to move for execution. The court granted the motion and issued a Writ of Execution. Petitioner Sheriff Josefino Ortiz of RTC-Las Piñas Br. 275 levied on Ocampo-Ferrer’s other real property in Las Piñas (covered by TCT No. 30480) and sold it at public auction, with Del Rosario as the highest bidder. Ocampo-Ferrer then filed a complaint before the RTC-Las Piñas, Branch 198 (RTC-Las Piñas Br. 198) seeking annulment of the sheriff’s sale and damages, claiming the enforcement was unlawful. Petitioners argued the complaint was barred by prior judgment and that RTC-Las Piñas Br. 198, a co-equal court, had no jurisdiction to annul actions from RTC-Las Piñas Br. 275. The RTC-Las Piñas Br. 198 dismissed the case for lack of merit. The Court of Appeals reversed, declaring the levy and sale null and void for procedural defects under the Rules of Court, specifically the sheriff’s failure to follow the proper sequence for levying property.
ISSUE
Whether or not the Court of Appeals correctly held that the levy and consequent sale of the property covered by TCT No. 30480 is null and void.
RULING
No. The Supreme Court granted the petition and set aside the CA Decision and Resolution. The Court ruled that the RTC-Las Piñas Br. 198 had no jurisdiction to take cognizance of the complaint (Civil Case No. LP-07-0037) seeking to annul the enforcement of a writ of execution issued by a co-equal court (RTC-Las Piñas Br. 275). This violates the doctrine of judicial stability or non-interference, which holds that no court can interfere with the judgments or orders of another court of concurrent jurisdiction. The court that issued the writ retains jurisdiction over its execution and all related incidents. The proper remedy to assail the enforcement of the writ was to seek redress from a higher court, not from a coordinate court. Consequently, Civil Case No. LP-07-0037 should have been dismissed for lack of jurisdiction. The Supreme Court did not reach the substantive issue regarding the procedural defects of the levy raised by the CA.