GR L 64149; (June, 1991) (Digest)
G.R. No. L-64149; June 19, 1991
THE SHELL COMPANY OF THE PHILIPPINES, LTD., petitioner, vs. HON. PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF AGUSAN DEL NORTE AND BUTUAN CITY, BRANCH II, SHERIFF OF MANILA and/or his deputy DOMINADOR Q. CACPAL, EUSTAQUIA SASTRE and EUGENE ONG, respondents.
FACTS
This case originated from a complaint for collection filed by respondent Eustaquia Sastre against petitioner Shell Company. The trial court rendered a decision ordering Shell to pay Sastre various sums, including P624,042.23 representing an overpayment. Shell appealed to the Court of Appeals, which affirmed the trial court’s decision with modifications only to the awards for damages and attorney’s fees, leaving the P624,042.23 award intact. Shell then elevated the case to the Supreme Court via a petition for review ( G.R. No. 56343 ), which was denied for lack of merit. The denial became final and executory.
Subsequently, the trial court issued a writ of execution to enforce the judgment. Shell filed the present petition for certiorari, prohibition, and mandamus, arguing that the trial court acted without jurisdiction in issuing the writ because the award of P624,042.23 was allegedly based on a misinterpretation of evidence. Shell contended that the checks presented as proof of overpayment were actually for a different purpose and that the computation was erroneous.
ISSUE
Whether the trial court acted without or in excess of its jurisdiction in issuing the writ of execution for the award of P624,042.23.
RULING
The Supreme Court dismissed the petition. The core legal principle applied is the finality of judgment and the doctrine of res judicata. The Court emphasized that the issue regarding the propriety of the P624,042.23 award had already been conclusively settled. This specific award was affirmed by the Court of Appeals and Shell’s subsequent petition for review before the Supreme Court ( G.R. No. 56343 ) was denied. That denial became final and executory, rendering the judgment immutable and unalterable.
The Court held that a final judgment can no longer be modified, and any error in the factual or legal assessment of the evidence is deemed cured by the judgment’s finality. Shell’s present attempt to re-litigate the correctness of the award through a petition for certiorari constitutes a collateral attack on a final judgment, which is impermissible. The trial court’s act of issuing the writ of execution was a ministerial duty to enforce a final judgment, not a jurisdictional error. Therefore, the trial court acted within its jurisdiction, and the extraordinary writs of certiorari and prohibition do not lie. The temporary restraining order was lifted.