GR L 53851; (July, 1991) (Digest)
G.R. No. L-53851 and G.R. No. L-63863; July 9, 1991
Chua Huat, et al., petitioners, vs. The Honorable Court of Appeals, et al., respondents.
FACTS
The consolidated cases stem from a final and executory 1972 decision in Civil Case No. 74634 for recovery of possession, ordering petitioners to vacate premises in Manila and pay rentals to the private respondents, Manuel Uy and Sons, Inc. and the Roman Catholic Archbishop of Manila. This decision was affirmed by the Court of Appeals and subsequently, petitions for review were denied by the Supreme Court. After finality, the trial court granted a motion for execution. Petitioners then filed separate actions for annulment of judgment before a different branch of the Court of First Instance, arguing the original case was an ejectment suit outside the trial court’s jurisdiction. The trial court refused to suspend execution, prompting a certiorari petition to the Court of Appeals, which was dismissed. Concurrently, city authorities issued condemnation and demolition orders for the subject buildings.
ISSUE
The primary issue is whether the filing of an action for annulment of judgment on the ground of lack of jurisdiction constitutes a supervening event that warrants the suspension of the execution of a final and executory judgment.
RULING
The Supreme Court dismissed the petitions, upholding the execution. The Court ruled that a final and executory judgment is immutable and unalterable. The alleged lack of jurisdiction of the trial court in the original case was not a supervening event but a matter that could and should have been, and was in fact, raised in the appeal. Petitioners exhausted their remedies through appeal, and the judgment attained finality. An action for annulment of judgment cannot be used to circumvent this finality, as it would violate the doctrine of immutability of judgments. The Court emphasized that a coordinate branch cannot interfere with the executing court’s duty to enforce its final decision. Regarding the demolition orders, the Court found petitioners failed to exhaust administrative remedies by not appealing to the Secretary of Public Works and Communications as required by law. Thus, no grave abuse of discretion was committed by the public respondents in issuing the notices and orders. The petitions were dismissed for lack of merit.