G.R. No. L-24874 September 30, 1978
CORNELIO MACANDILE, petitioner, vs. HON. ARTEMIO C. MACALINO, as Executive Judge of the Court of Agrarian Relations and Presiding Judge of the Court of Agrarian Relations, Seventh Regional District, Los Baños Laguna, SOTERA GUEVARRA, PEPITO TICZON and BEATRIZ TICZON, respondents.

FACTS

Petitioner Cornelio Macandile filed a complaint to be declared an agricultural tenant on a coconut landholding. The parties entered into a compromise agreement, which was approved by Judge Pastor L. de Guzman in a decision dated August 8, 1962. However, the same decision contained a finding that the petitioners were “not tenants but merely watchers.” Macandile moved for reconsideration. Judge de Guzman subsequently set aside his own decision on October 25, 1962, ruling the amicable settlement was against law, morals, and public policy. The case was set for further proceedings.
Before the case could be resolved on the merits, Judge de Guzman was reassigned. Executive Judge Artemio C. Macalino was then tasked with resolving the pending motion for reconsideration. In a resolution dated May 5, 1964, Judge Macalino recognized Macandile as the tenant on the landholding. However, upon a motion for reconsideration from the landowners, Judge Macalino issued a second resolution on July 15, 1964, which is the subject of this certiorari petition. In this resolution, he set aside his own May 5 ruling on the ground of “comity among judges,” revived Judge de Guzman’s original March 15, 1963 decision (which held Macandile was not a tenant), and ordered that the pending motions be resolved by the now-reassigned Judge de Guzman.

ISSUE

Whether or not respondent Judge Macalino committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the July 15, 1964 resolution.

RULING

Yes, the Supreme Court granted the petition and annulled the July 15, 1964 resolution. The Court held that Judge Macalino committed grave abuse of discretion. The principle of “comity among judges” is not a valid legal ground to set aside a resolution that had already attained finality. Judge Macalino’s May 5, 1964 resolution, which recognized Macandile’s tenancy, was a final order on the matter it resolved. It was issued by a judge with competent jurisdiction and was not appealed. Therefore, it became immutable and unalterable.
The legal logic is anchored on the doctrine of finality of judgments and the principle of immutability. Once a final order is issued by a court of competent jurisdiction, it cannot be disturbed or modified by the same court, save for specific exceptions like clerical errors or judgments void upon their face. Judge Macalino’s attempt to revive a prior decision of a reassigned judge, based merely on comity, violated this fundamental rule. His act of reopening a finally settled issue constituted an arbitrary and whimsical exercise of power, which is the essence of grave abuse of discretion. The Court emphasized that judicial comity cannot override substantive rules of procedure and the rights of parties vested under a final order. The subsequent sale of the landholdings to third parties, as reported, rendered the specific issue of reinstatement moot, but did not negate the legal error committed by the judge, which the Court corrected to prevent a precedent for arbitrary disregard of final orders.