GR L 24787; (February, 1974) (Digest)
G.R. No. L-24787 February 22, 1974
TUMIPUS MANGAYAO AND GUIMANDA BUBUNGAN, petitioners, vs. HONORABLE DOROTEO DE GUZMAN, SANTAY LASUD, AND GUINTANA CIA LASUD, respondents.
FACTS
Petitioners, non-Christian Filipinos of the Subano tribe, filed an action for recovery of property and declaration of nullity of contract against private respondents. They obtained a favorable decision from the Court of First Instance of Zamboanga del Sur, which was affirmed by the Supreme Court on May 29, 1964. This judgment became final and executory on October 5, 1964, and petitioners were placed in possession of the property on April 1, 1965. Subsequently, private respondents filed a new action before respondent Judge Doroteo de Guzman for the annulment of the very same final and executory judgment. Respondent Judge issued an order restraining petitioners from executing the Supreme Court’s affirmed decision, prompting petitioners to file this certiorari proceeding.
ISSUE
Whether the respondent Judge acted without or in excess of jurisdiction or with grave abuse of discretion in issuing a restraining order against the execution of a final and executory judgment of the Supreme Court and in entertaining a new action seeking its annulment.
RULING
The Supreme Court granted the petition, nullified the respondent Judge’s order, and directed the dismissal of the new annulment case. The ruling is anchored primarily on the doctrine of the “law of the case.” A decision of the Supreme Court that has become final and executory constitutes the law of that particular case and is binding on all inferior courts. It is beyond their power to alter, modify, or review. The attempt by private respondents to relitigate the matter through a new action for annulment was a direct assault on this final judgment. The Court emphasized that the Supreme Court is the final arbiter of legal questions, and its final judgments are not subject to review or reversal by any other court.
Furthermore, the Court found the respondent Judge’s actuation inexplicable and unjustifiable. An independent review of the substantive merits of the original case, as reflected in the 1964 Supreme Court decision, reinforced this conclusion. That decision had definitively ruled that the conveyance by the illiterate non-Christian petitioners was void ab initio for lack of the required executive approval, a ruling grounded in protective statutes and the constitutional principle of social justice. Therefore, irrespective of the procedural bar imposed by the law of the case doctrine, the petition was meritorious on substantive grounds as well. The Court made permanent the preliminary injunction it had previously issued.