G.R. No. L-5224 March 26, 1953
Domingo Luis and Emilia Luis, petitioners, vs. Antonio Belmonte, et al., respondents.

FACTS

The Supreme Court, in a prior criminal case (People vs. Antonio Guillermo), convicted Antonio Guillermo of seven murders, sentencing him to life imprisonment and ordering him to indemnify the heirs of each victim, including the heirs of Donato Luis (the petitioners), P6,000. After this decision became final, the case was remanded to the Court of First Instance of Ilocos Norte for execution. However, the lower court, upon motion of the accused and his bondsmen, suspended execution by ordering that promulgation be held in abeyance pending the determination of Guillermo’s petition for amnesty before the Seventh Amnesty Commission. The petitioners, as heirs of victim Donato Luis, filed this action for mandamus, alleging it was the lower court’s ministerial duty to execute the Supreme Court’s judgment immediately and that the suspension was without authority and constituted grave abuse of discretion. The record shows Guillermo had previously attempted to delay execution by filing a motion with the Supreme Court to suspend proceedings and refer the case to the Amnesty Commission, which was denied. Furthermore, the Solicitor General had already successfully obtained a writ of prohibition from the Supreme Court (in G.R. No. L-4316, People vs. Macadaeg) against the Amnesty Commission, ruling that Guillermo was not entitled to amnesty, that this finding was res judicata, and that the Commission had no jurisdiction over his petition.

ISSUE

Whether the lower court acted without authority and with grave abuse of discretion in suspending the execution of a final Supreme Court judgment convicting Antonio Guillermo, thereby warranting the issuance of a writ of mandamus to compel immediate execution.

RULING

The Supreme Court granted the petition for a writ of mandamus. The Court held that the interests of justice demand that final judgments be executed without unnecessary delay. It noted that the issue of Guillermo’s entitlement to amnesty had already been conclusively settled by the Court’s final decision in the prohibition case (G.R. No. L-4316), which declared he was not entitled to amnesty and that the Amnesty Commission had no jurisdiction. That prior ruling constituted res judicata and should have ended all attempts to delay execution based on a pending amnesty petition. The petitioners, as heirs awarded indemnity in the criminal judgment, had a direct interest in its execution. Therefore, the lower court’s order suspending execution was unauthorized. The writ of mandamus was issued to compel the execution of the judgment, with costs against respondent Antonio Guillermo.