G.R. No. 76838 ; April 17, 1990
LUALHATI A. COJUANGCO, petitioner, vs. PURIFICACION VILLEGAS and the PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH XVII, MALOLOS, BULACAN, respondents.

FACTS

Petitioner Lualhati Cojuangco is the widow of the registered owner, Don Juan Cojuangco, of a parcel of land in Malolos, Bulacan. Private respondent Purificacion Villegas and her parents had occupied the land for decades with the owner’s permission, on condition they would vacate when needed. After her parents’ death, Villegas remained, made renovations, and leased a portion without consent. Following demands to vacate, an ejectment case was filed against her. The case progressed through the Municipal Trial Court, the then Court of First Instance (CFI), the appellate court, and the Supreme Court, with Cojuangco’s right of possession being ultimately upheld. After the decision became final, the CFI (sitting as RTC Branch XV) granted Cojuangco’s motion for execution and issued a writ of demolition.
Before the demolition could be effected, Villegas filed a separate civil action for specific performance against Cojuangco and the sheriff, claiming rights as a builder in good faith entitled to indemnification. This new case was raffled to a different branch of the same RTC, Branch XVII, which then issued a temporary restraining order and later a writ of preliminary injunction, enjoining the enforcement of the demolition order from the concluded ejectment case.

ISSUE

Whether the Regional Trial Court, Branch XVII, committed grave abuse of discretion in issuing injunctive relief that interfered with the final and executory judgment of a co-equal court (RTC Branch XV) in the ejectment case.

RULING

Yes. The Supreme Court granted the petition, annulled the proceedings in Civil Case No. 9094-M, and ordered the immediate execution of the ejectment judgment. The Court held that the respondent court (Branch XVII) committed grave abuse of discretion amounting to lack of jurisdiction. The established doctrine, as cited in Cabigao v. Del Rosario, prohibits a court from interfering by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction. The various branches of the RTC in a province or city exercise concurrent and coordinate jurisdiction; they are not permitted to interfere with each other’s orders or judgments, as such interference leads to confusion and obstructs the administration of justice.
Furthermore, Villegas’s claim for compensation as a builder in good faith was essentially a compulsory counterclaim that arose from the same transaction—her possession of the land. Under the Rules of Court, such a counterclaim is barred if not set up in the original ejectment suit. The respondent court’s justification that the injunction was necessary to prevent rendering Villegas’s claim “meaningless” was untenable. The legal priority is the execution of a final ejectment judgment, which is designed to be immediately executory to prevent further damage to the prevailing party. The equities favored the landowner, Cojuangco, as Villegas and her family had occupied the land for over half a century without paying rent. Therefore, the injunction constituted an undue interference and was improperly issued.