G.R. No. L-13324; October 31, 1961
MARCELO CAGUIOA, ET AL., petitioners, vs. THE BACOLOD-MURCIA FARMERS’ CORPORATION represented by HIEROTEO R. VILLAROSA, respondents.

FACTS

The Bacolod-Murcia Farmers’ Corporation filed a mandamus petition in the Court of First Instance of Negros Occidental to compel Permit Agent Salvador Pacis of the Sugar Quota Administration to sign the permit portions of quedan-permits for sugar milled and stored. Pacis refused, citing instructions from the Secretary of Commerce and Industry to recognize a rival planters’ association pending resolution of a separate civil case. The trial court, under Judge Eduardo E. Enriquez, granted the writ, ordering Pacis to sign the permits immediately. After the decision became final, the court granted a motion for immediate execution. As Pacis could not be located, the court ordered Marcelo Caguioa, the Acting District Sugar Supervisor, to sign the permits in Pacis’s stead. When Caguioa refused, the court further ordered the Clerk of Court to sign them and initiated contempt proceedings against both Pacis and Caguioa.
Caguioa and Pacis then filed this certiorari and prohibition case, arguing the trial judge acted without jurisdiction and with grave abuse of discretion. They contended Caguioa was not a party to the original mandamus case and could not be compelled to perform Pacis’s duty. They also asserted that ordering Caguioa to act amended the final decision without proper motion.

ISSUE

Whether the trial court acted with grave abuse of discretion or in excess of jurisdiction in ordering Marcelo Caguioa, the Acting District Sugar Supervisor, to sign the quedan-permits in lieu of the original respondent, Permit Agent Salvador Pacis, and in holding him liable for contempt for refusal.

RULING

The Supreme Court dismissed the petition. The legal logic is anchored on the nature of the duty involved and the court’s authority to enforce its final and executory judgments. The duty to sign the quedan-permits was a ministerial duty imposed by law on the Sugar Quota Administrator. Both Pacis, the Permit Agent, and Caguioa, the Acting District Sugar Supervisor, were subordinates and representatives of this Administrator within the milling district, effectively acting in the same official capacity concerning the quota function. The mandamus decision against Pacis had become final and unappealed, and its validity was implicitly upheld by the Supreme Court in a related resolution allowing its immediate execution.
Consequently, the trial court possessed inherent authority to ensure the execution of its lawful judgment. When Pacis became unavailable, the court properly ordered Caguioa, as the ranking official in the district exercising the same administrative function, to perform the act to give effect to the writ. This was a valid exercise of the court’s power under the Rules of Court to direct the act to be done by “any other person” capable of performing the duty, a power ultimately demonstrated when the Clerk of Court was also authorized to sign. Caguioa’s refusal to obey a lawful order from a court of competent jurisdiction, which he was bound to follow as an officer of the court, properly rendered him amenable to contempt proceedings. The Court found no jurisdictional error or abuse of discretion in the trial court’s orders to achieve the execution of its final judgment.