G.R. No. L-71365, June 18, 1987
Paper Industries Corporation of the Philippines, petitioner, vs. The Honorable Intermediate Appellate Court, The Honorable Roque A. Tamayo, Presiding Judge, Regional Trial Court, National Capital Judicial Region, Branch 132, Makati, Metro Manila, and Vicmar Development Corporation, respondents.

FACTS

Petitioner Paper Industries Corporation of the Philippines (PICOP) obtained a favorable judgment against private respondent Vicmar Development Corporation from Branch 145 (Madayag court) of the Makati RTC. Vicmar paid the principal debt but refused to pay accrued interests and attorney’s fees, claiming an alleged waiver. The Madayag court issued a writ of execution for the unpaid amount on June 6, 1984. The sheriff levied on Vicmar’s properties. On October 14, 1984, the sheriff levied on Vicmar’s logs, which were later auctioned and sold to PICOP. Vicmar then filed a new complaint before Branch 132 (Tamayo court) of the same Makati RTC, styled as an action for damages with a prayer for a preliminary injunction, seeking to nullify the sheriff’s proceedings. The Tamayo court issued restraining orders against the sheriff. PICOP moved to dismiss this new case, arguing that Branch 132 had no jurisdiction to interfere with the execution proceedings of a coordinate court.

ISSUE

Whether Branch 132 of the Makati Regional Trial Court has jurisdiction to take cognizance of Civil Case No. 9301 and issue restraining orders against the execution of a final judgment rendered by Branch 145 of the same court.

RULING

No. The Supreme Court ruled that Branch 132 (Tamayo court) acted without jurisdiction and abused its discretion in entertaining the action and issuing restraining orders. The legal logic is anchored on the principle of judicial stability and the prohibition against interference by coordinate and co-equal courts. The various branches of a regional trial court in a single station are courts of equal and concurrent jurisdiction. One branch cannot, through an independent action, nullify or restrain the execution of a final and executory judgment rendered by another branch. The proper remedy for any alleged irregularity in the execution proceedings is to seek relief from the court that rendered the judgment and issued the writ—in this case, Branch 145.
The Court examined the amended complaint in Civil Case No. 9301 and found that, although captioned as an action for damages, its substance directly assailed the validity of the writ of execution issued by Branch 145 and the sheriff’s implementation thereof. Specifically, it questioned the levy on the logs as being pursuant to a “dead writ,” as the execution was enforced beyond the 60-day period under the Rules. This characterization does not transform it into an independent action that can be validly lodged in a coordinate court. The Supreme Court, citing precedents like Buan v. Matugas and Hubahib v. Insular Drug Co., emphasized that to allow such a practice would undermine judicial orderly processes and sanction conflict between courts of equal rank. Therefore, Branch 132 should have dismissed the case for lack of jurisdiction. The execution proceedings and any related incidents fall under the exclusive jurisdiction of Branch 145. The decision of the Intermediate Appellate Court was reversed and set aside.